Estudo de Caso em Tunel
Estudo de Caso em Tunel
Estudo de Caso em Tunel
Prepared For
Massachusetts Turnpike Authority
by
Bechtel/Parsons Brinkerhoff
Operating Certification of the Project Ventilation System
Table of Contents
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CA/T Project: Technical Support Document
LIST OF FIGURES
FIGURE 1-1: PHYSICAL LIMITS OF CA/T PROJECT .............................................................................................1–2
FIGURE 1-2: SCHEMATIC OF FULL-TRANSVERSE VENTILATION SYSTEM ...........................................................1–4
FIGURE 1-3: VENTILATION BUILDING 4 VENTILATION SCHEMATIC DIAGRAM ..................................................1–4
FIGURE 1-4: LOCATION OF VENTILATION BUILDINGS ........................................................................................1–5
FIGURE 1-5: LOCATION OF VENTILATION BUILDING 1.......................................................................................1–6
FIGURE 1-6: LOCATION OF VENTILATION BUILDING 3.......................................................................................1–7
FIGURE 1-7: LOCATION OF VENTILATION BUILDING 4.......................................................................................1–8
FIGURE 1-8: LOCATION OF VENTILATION BUILDING 5.......................................................................................1–9
FIGURE 1-9: LOCATION OF VENTILATION BUILDING 6.....................................................................................1–10
FIGURE 1-10: LOCATION OF VENTILATION BUILDING 7.....................................................................................1–11
FIGURE 1-11: LOCATION OF EXISTING AND FUTURE DST EXIT PORTAL ...........................................................1–14
FIGURE 1-12: LOCATION OF RAMP PORTALS 1(L-CS) AND 3 (SA-CN) .............................................................1–15
FIGURE 1-13: LOCATIONS OF RAMP PORTAL 2 (CN-S)......................................................................................1–16
FIGURE 1-14: LOCATIONS OF RAMP PORTALS 4 (ST-CN) AND 5 (ST-SA) ........................................................1–17
FIGURE 1-15: LOCATIONS OF RAMP PORTAL 6 (CS-SA) ...................................................................................1–18
FIGURE 1-16: LOCATION OF RAMP PORTAL 7 (CS-P) ........................................................................................1–19
FIGURE 1-17: LOCATION OF RAMP PORTAL 8 (F) ..............................................................................................1–20
FIGURE 1-18: SUPPLY FAN AT VB 7 AIR INTAKE FLOOR ...................................................................................1–23
FIGURE 1-19: JET FAN AT LONGITUDINALLY VENTILATION RAMP ....................................................................1–25
FIGURE 2-1: CO/NOX RELATIONSHIP BASED ON MONITORED LEVELS AT THE TED WILLIAMS TUNNEL .........2–31
FIGURE 2-2: STACK CONFIGURATION VENTILATION BUILDING 1 ....................................................................2–36
FIGURE 2-3: STACK CONFIGURATION VENTILATION BUILDING 3 ....................................................................2–37
FIGURE 2-4: STACK CONFIGURATION VENTILATION BUILDING 4 ....................................................................2–38
FIGURE 2-5: STACK CONFIGURATION VENTILATION BUILDING 5 ....................................................................2–39
FIGURE 2-6: STACK CONFIGURATION VENTILATION BUILDING 6 ....................................................................2–40
FIGURE 2-7: STACK CONFIGURATION VENTILATION BUILDING 7 ....................................................................2–41
FIGURE 2-8: RAMP L-CS .................................................................................................................................2–46
FIGURE 2-9: RAMP SA-CN ..............................................................................................................................2–47
FIGURE 2-10: RAMP CN-S .................................................................................................................................2–48
FIGURE 2-11: RAMP ST-SA ...............................................................................................................................2–49
FIGURE 2-12: RAMP CS-SA...............................................................................................................................2–50
FIGURE 2-13: RAMP CS-P..................................................................................................................................2–51
FIGURE 2-14: RAMP F........................................................................................................................................2–52
FIGURE 2-15: DEWEY SQUARE TUNNEL – CONFIGURATION 1 ............................................................................2-54
FIGURE 2-16: DEWEY SQUARE TUNNEL – CONFIGURATION 2 ............................................................................2-55
FIGURE 2-17: DEWEY SQUARE TUNNEL – CONFIGURATION 3A .........................................................................2-56
FIGURE 2-18: CTPS MODELED AREA .................................................................................................................2-66
FIGURE 2-19: CA/T PROJECT STUDY AREA ........................................................................................................2-67
FIGURE 4-1: ORGANIZATIONAL STRUCTURE FOR THE MTA-CA/T PROJECT CONTINUOUS AIR
EMISSIONS MONITORING PROGRAM .............................................................................................4-88
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LIST OF TABLES
TABLE 1-1: VENTILATION BUILDING AND EXHAUST STACK HEIGHTS ...........................................................1–23
TABLE 1-2: VENTILATION BUILDINGS EXHAUST CAPACITY FOR VARYING STEPS .........................................1–24
TABLE 1-3: LONGITUDINAL VENTILATION TUNNEL SECTION DIMENSIONS AND MECHANICAL
VENTILATION CAPACITIES ...........................................................................................................1–25
TABLE 1-4: TRAFFIC VOLUMES, SPEEDS AND AIR FLOW RATES FOR DST AND EIGHT
LONGITUDINALLY VENTILATED RAMPS ......................................................................................1–26
TABLE 2-1: CO/NOX RELATIONSHIP BASED ON AUGUST 2004 MEASURED DATA .........................................2–31
TABLE 2-2: CO LEVELS AT ROXBURY MONITORING STATION .......................................................................2–32
TABLE 2-3: NO2 ANNUAL LEVELS AT ROXBURY MONITORING STATION .......................................................2–33
TABLE 2-4: PM10 LEVELS AT NORTH END MONITORING STATION .................................................................2–33
TABLE 2-5: MAXIMUM 1-HOUR CO CONCENTRATIONS FROM VENTILATION BUILDINGS AT AMBIENT
RECEPTORS FOR COMPLIANCE DEMONSTRATION ........................................................................2–35
TABLE 2-7: MODEL INPUT PARAMETERS FOR VENTILATION BUILDINGS ........................................................2–42
TABLE 2-6: MAXIMUM 8-HOUR CO CONCENTRATIONS FROM VENTILATION BUILDINGS AT AMBIENT
RECEPTORS FOR COMPLIANCE DEMONSTRATION ........................................................................2–43
TABLE 2-8: MAXIMUM 1-HOUR NO2 CONCENTRATIONS FROM VENTILATION BUILDINGS AT AMBIENT
RECEPTORS FOR COMPLIANCE DEMONSTRATION ........................................................................2–43
TABLE 2-9: MAXIMUM ANNUAL NO2 CONCENTRATIONS FROM VENTILATION BUILDINGS AT AMBIENT
RECEPTORS FOR COMPLIANCE DEMONSTRATION ........................................................................2–44
TABLE 2-10: MAXIMUM 24-HOUR PM10 CONCENTRATIONS FROM VENTILATION BUILDINGS AT
AMBIENT RECEPTORS FOR COMPLIANCE DEMONSTRATION ........................................................2–44
TABLE 2-11: MAXIMUM ANNUAL PM10 CONCENTRATIONS FROM VENTILATION BUILDINGS FOR
COMPLIANCE DEMONSTRATION ..................................................................................................2–45
TABLE 2-12: 1- AND 8-HOUR CO LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP LC-S .........................2-58
TABLE 2-13: 1- AND 8-HOUR CO LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP SA-CN......................2-58
TABLE 2-14: 1- AND 8-HOUR CO LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP CN-S.........................2-58
TABLE 2-15: 1- AND 8-HOUR CO LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP ST-CN NO
PARCEL 6 ......................................................................................................................................2-59
TABLE 2-16: 1- AND 8-HOUR CO LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP ST-SA
NO PARCEL 6 ................................................................................................................................2-59
TABLE 2-17: 1- AND 8-HOUR CO LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP ST-SA +
PARCEL 6......................................................................................................................................2-59
TABLE 2-18: 1- AND 8-HOUR CO LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP CS-SA +
PARCEL 12....................................................................................................................................2-59
TABLE 2-19: 1- AND 8-HOUR CO LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP CS-SA
NO PARCEL 12 ..............................................................................................................................2-59
TABLE 2-20: 1- AND 8-HOUR CO LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP CS-P .........................2-60
TABLE 2-21: 1- AND 8-HOUR CO LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP F................................2-60
TABLE 2-22: 1- AND 8-HOUR CO LEVELS FOR COMPLIANCE DEMONSTRATION –
DEWEY SQUARE TUNNEL: CONFIGURATION 1.............................................................................2-60
TABLE 2-23: 1- AND 8-HOUR CO LEVELS FOR COMPLIANCE DEMONSTRATION –
DEWEY SQUARE TUNNEL: CONFIGURATION 2.............................................................................2-60
TABLE 2-24: 1- AND 8-HOUR CO LEVELS FOR COMPLIANCE DEMONSTRATION –
DEWEY SQUARE TUNNEL: CONFIGURATION 3A..........................................................................2-60
TABLE 2-25: 1-HOUR NO2 LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP LC-S ....................................2-61
TABLE 2-26: 1-HOUR NO2 LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP SA-CN.................................2-61
TABLE 2-27: 1-HOUR NO2 LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP CN-S ...................................2-62
TABLE 2-28: 1-HOUR NO2 LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP ST-CN NO PARCEL 6 ...........2-62
TABLE 2-29: 1-HOUR NO2 LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP ST-SA NO PARCEL 6............2-62
TABLE 2-30: 1-HOUR NO2 LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP ST-SA + PARCEL 6..............2-62
TABLE 2-31: 1-HOUR NO2 LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP CS-SA + PARCEL 12............2-63
TABLE 2-32: 1-HOUR NO2 LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP CS-SA NO PARCEL 12 .........2-63
TABLE 2-33: 1-HOUR NO2 LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP CS-P ....................................2-63
TABLE 2-34: 1-HOUR NO2 LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP F ..........................................2-63
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TABLE 2-35: 1-HOUR NO2 LEVELS FOR COMPLIANCE DEMONSTRATION: DEWEY SQUARE TUNNEL –
CONFIGURATION 1 ........................................................................................................................2-64
TABLE 2-36: 1-HOUR NO2 LEVELS FOR COMPLIANCE DEMONSTRATION : DEWEY SQUARE TUNNEL –
CONFIGURATION 2 ........................................................................................................................2-64
TABLE 2-37: 1-HOUR NO2 LEVELS FOR COMPLIANCE DEMONSTRATION : DEWEY SQUARE TUNNEL –
CONFIGURATION 3A .....................................................................................................................2-64
TABLE 2-38: PROJECTS INCLUDED IN THE BUILD AND NO-BUILD NETWORKS ..................................................2-68
TABLE 2-39: NETWORK-BASED DAILY VMT AND VOCS..................................................................................2-70
TABLE 2-40: MBTA BUSES DAILY VMT AND VOCS .......................................................................................2-70
TABLE 2-41: COMMUTER RAILROAD DAILY VMT AND VOCS .........................................................................2-70
TABLE 2-42: FERRY DAILY FUEL CONSUMPTION AND VOCS ...........................................................................2-70
TABLE 2-43: TOTAL DAILY VOC EMISSIONS ....................................................................................................2-71
TABLE 2-44: OPERATING LIMITS FOR VENTILATION BUILDINGS .......................................................................2-71
TABLE 2-45: OPERATING LIMITS FOR LONGITUDINALLY –VENTILATED RAMPS ...............................................2-72
TABLE 4-48: KEY PERSONNEL AND RESPONSIBILITIES ......................................................................................4-87
TABLE 5-1: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS:
VENTILATION BUILDING 1 ............................................................................................................5-93
TABLE 5-2: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS:
VENTILATION BUILDING 3 ............................................................................................................5-95
TABLE 5-3: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS:
VENTILATION BUILDING 4 ............................................................................................................5-97
TABLE 5-4: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS:
VENTILATION BUILDING 5 ............................................................................................................5-99
TABLE 5-5: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS:
VENTILATION BUILDING 6 ..........................................................................................................5-101
TABLE 5-6: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS:
VENTILATION BUILDING 7 ..........................................................................................................5-102
TABLE 5-7: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: RAMP LC-S.........................5-105
TABLE 5-8: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: RAMP SA-CN .....................5-105
TABLE 5-9: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: RAMP CN-S ........................5-106
TABLE 5-10: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: RAMP CS-SA ......................5-106
TABLE 5-11: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: RAMP CS-P.........................5-107
TABLE 5-12: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: RAMP F ...............................5-107
TABLE 5-13: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: DST I-93 ............................5-108
TABLE 5-14: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: DST I-90 ............................5-108
TABLE 6-1: SUMMARY OF EMISSION LIMITS..................................................................................................6-109
TABLE 6-2: EMISSION ACTION LEVELS .........................................................................................................6-110
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Executive Summary
The Central Artery/Tunnel (CA/T) Project in Boston, Massachusetts includes approximately 160 lane-
miles of new highway, of which approximately 3.6 miles (or 80 lane-miles) are underground tunnels.
This includes the 7,900-foot-long, four-lane Ted Williams Tunnel (TWT) under Boston Harbor
connecting South Boston and East Boston, the eight- to ten-lane underground Southeast Expressway
(I-93), and the underground portions of the Massachusetts Turnpike (I-90). The entire CA/T Project was
opened to general public use on March 5, 2005.
The CA/T’s ventilation system utilizes a mixture of full-transverse ventilation and longitudinal
ventilation. The vast majority of the tunnels operate as a full-transverse ventilation system. In the full
transverse ventilation system, fresh air is introduced to the tunnels from under the roadway, and the
exhaust air is extracted through openings in the tunnel ceilings to plenums located above the ceiling. The
ventilation fans and auxiliary equipment that provide fresh air and exhaust air are housed in the six
ventilation buildings (VBs 1, 3, 4, 5, 6, and 7).
The portion of I-93 called the Dewey Square Tunnel (DST) and eight exit ramps of the CA/T roadway are
longitudinally ventilated. In the longitudinal ventilated tunnels, exhaust air moves in the direction of the
traffic flow. In doing so, tunnel exhaust air is pushed through and out the exit portals of the tunnel by the
piston action effect created by moving vehicles. In all, nine sections of CA/T roadway are ventilated to
the outside air by longitudinal ventilation. Some longitudinally ventilated tunnels include supply air and
jet fans mounted in the tunnel ceilings. Two VBs provide fresh air to two longitudinally ventilated tunnel
sections (VB 8, and DST Air Intake Structure).
Massachusetts Department of Environmental Protection (Mass DEP) Regulation 310 CMR 7.38(2) states
that no person shall construct a tunnel ventilation system and project roadway subject to 310 CMR 7.00
without first certifying to Mass DEP (and receiving Mass DEP written acceptance of that certification),
that the operation of any tunnel ventilation system, project roadway and roadway networks will not cause
a violation of certain specified standards, guidelines and criteria specified in CMR 7.38. On July 8, 1991,
Mass DEP conditionally accepted the CA/T Project’s Pre-Construction Certification. An Amended Pre-
Construction Certification was conditionally accepted by Mass DEP on September 1, 2000. Under Mass
DEP Regulation 310 CMR 7.38(4), the CA/T Project is required to file an Operating Certification for the
Project’s ventilation system (“Operating Certification”), which establishes emission limits for the exhaust
from each VB and longitudinal ventilated exit ramp. The Operating Certification is required to be filed
no earlier than 12 months and no later than 15 months after the entire CA/T Project was opened to public
use. There are four parts to the Operating Certification:
• Part I – Ventilation System – Operation and Emission Limits
• Part II – Compliance Monitoring Program
• Part III – Record Keeping and Reporting
• Part IV – Corrective Actions
This Technical Support Document (TSD) provides specific information for the CA/T’s Operating
Certification. Mass DEP’s Conditional Acceptance of the CA/T Project’s Pre-Construction Certification
required certain mitigation measures to mitigate potential air quality impacts from the CA/T Project and
to meet the criteria set forth in the Ventilation Certification Regulation for proposed certification. As was
demonstrated in the 1991 Pre-Construction Certification, and as is discussed in detail in the TSD, the
CA/T Project, as currently constructed and operated, complies with all relevant air quality standards in the
Project area. The data collected for the Operating Certification demonstrates that the CA/T Project has
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not had a negative effect on local air quality. Future CA/T data collected as part of this Operating
Certification along with contingency measures outlined in this document, should demonstrate that the
CA/T Project will continue to have a positive effect on local air quality. In addition, data collected for the
Operating Certification also demonstrates that the CA/T Project, as currently constructed and operated,
satisfies the criteria set forth in the Ventilation Certification Regulation for project certification, as
demonstrated through actual measured emissions.
Part I describes in detail, the CA/T’s ventilation system and pollutant emission limits that were
established for the exhaust from the ventilation buildings and the longitudinally ventilated tunnel sections
(DST and exit ramps). Since the Project tunnels are open for general public use under normal operation,
the tunnel ventilation system has been designed with redundant ventilation capacity to adequately protect
motorists traveling the tunnels. The established emission limits are being applied to day-to-day tunnel
operation not including emergency situations during a tunnel fire.
Recently, exhaust plenum modifications have been made to the I-90 Connector after several exhaust
plenum panels directly beneath the D-Street overpass of the eastbound Connector tunnel, near its exit
portal, fell to the roadway below it. These modifications involved removal of exhaust panels within
approximately 200 feet of the eastbound exit portal and within approximately 150 feet of the westbound I-
90 Connector entrance portal. The small amount of emissions generated within the last 200 feet section,
instead of being picked up by VB 5 as originally designed, will be carried forward directly into the open
boat section between the I-90 Connector and Ted Williams Tunnel by the air flow created by vehicles
exiting the tunnel (i.e., this short section will become naturally ventilated). Qualitative assessment of air
quality conditions indicates that there will be no significant air quality consequences as a result of these
modifications.
The emission limits for carbon monoxide (CO), nitrogen oxides (NOx) and particulate matter smaller than
10 micron (PM10) were determined as concentration-based emission limits (i.e., measured levels in parts
per million [ppm] or micrograms per cubic meter [μg/m3] inside the tunnels). Through dispersion
modeling, using both the US Environmental Protection Agency (EPA) approved air models and wind
tunnel test techniques, compliance demonstrations of the applicable ambient air quality standards and
state guideline values (for CO, NO2 and PM10) have been made for all conditions when the tunnels are
operated below these limits. Since there are no ambient air quality standards for volatile organic
compounds (VOCs), 310 CMR 7.38 requires that the Project does not increase emissions over the No-
Build scenario at a regional level. A regional emission inventory for the transportation sources included
in the CA/T Project study area was performed for year 2005 including both the CA/T Build and No-Build
scenarios. The results of this inventory indicate that the CA/T Project and transit projects completed by
the Commonwealth to date, have resulted in the reduction of emissions versus the No-Build scenario.
The procedures used in these analyses, which have been approved by the Mass DEP (see Appendix F,
“Mass DEP Correspondence”), are included in Appendix B, “Air Quality Analysis Protocol for
Determination of Emission Limits as Part of the Operating Certification of the Project Ventilation
Systems”.
Part II of the TSD describes the CA/T’s compliance monitoring program, including the Continuous
Emissions Monitoring (CEM) system designed, constructed and installed to demonstrate compliance with
established emission limits. The CEM system is operated independent of the CO monitors which were
installed along the tunnel sections and are used to control the ventilation levels. These in-tunnel CO
monitors are used to aid the operators to maintain safe air quality and visibility within the tunnels under
normal operations and to control smoke and heat during emergency conditions.
Due to the low pollution levels inside the tunnels (i.e., higher than ambient but much lower than industrial
stacks), the CEM system is considered a hybrid type of monitoring system, which incorporates
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appropriate elements of the federal regulations 40 CFR Part 58, 60, and 75 for both the ambient air quality
monitoring systems and the continuous emission monitoring at power plants. Equipment certification and
operations are specifically tailored for use in the Project’s emission monitoring program, and its Initial
Certification of the Project CEM Systems was performed in 2005. Attachment 1, “CEM Air Emissions
Monitoring Protocol”, provides specific information regarding CEM equipment that has been installed at
each VB and longitudinal ventilated exit ramp as well as the operational protocol for the CEM equipment.
The project-wide quality assurance and quality control (QA/QC) program has been developed through
extensive technical consultation with the Mass DEP (see Appendix F, “Mass DEP Correspondence”).
The procedures to be followed also take into account equipment manufacturer’s recommendations as well
as good engineering practice.
Vehicular emissions (i.e., CO) in the tunnel are monitored in the exhaust plenum of each ventilation zone
prior to being discharged up and out of the building stacks and at the exit portal of each longitudinal
ventilated exit ramps. In lieu of monitoring, the NOx emission levels are estimated using the monitored
CO emission levels measured at the plenum. CO–NOx correlation models were developed based on the
statistical analysis of several thousand hours of monitored data for both pollutants at the TWT. The PM10
emissions are monitored at four representative locations where the highest PM10 levels have been
identified.
Part III describes the record keeping and reporting aspects of the CA/T’s Operating Certification. All CO
and PM10 CEM data are recorded continuously at each CEM location and the data is downloaded via a
modem to a central PC. These data are reviewed and daily data summaries for each month are generated.
Using the daily summaries, NOx emission concentrations are developed using the Project-specific CO to
NOx conversion ratio.
In support of the Operating Certification, seven months of these CEM data (i.e., October through April
2006) are included in this document. Starting in May 2006, these data will be compiled and submitted to
the Mass DEP on a monthly basis for the period from May 2006 through October 2007, and on a
quarterly basis thereafter.
As part of the Operating Certification requirements, the CA/T Project is also collecting and recording
traffic data in the mainline tunnels. Hourly and daily traffic volumes for both directions in I-93 and I-90
are being recorded and will be submitted monthly to Mass DEP from October 2006 to October 2007, and
on a quarterly basis thereafter.
Part IV of the TSD describes corrective actions that will be taken by the Massachusetts Turnpike
Authority (MTA) in the unlikely event that any of the established emissions limits are exceeded due to
non-emergency traffic conditions. Written notification of an exceedance, along with the actions that have
been taken to eliminate it, will then be submitted to the Mass DEP.
Current peak-hour traffic volumes using the mainline tunnels (i.e., I-93 & I-90) are between 60 to 80% of
the projected year 2010 peak-hour levels. The Project tunnel ventilation system currently is operating at
13% of its exhaust capacity during off-peak and night hours and at 23 to 32% capacity during peak hours.
There is thus more than sufficient capacity in the Project’s ventilation system to address future increase in
emissions.
Hourly CEM data have been collected since October 2005 and the results indicate that the measured CO
concentrations range from 1 to 6 ppm during off-peak and as high as 26 ppm during peak periods. The
NOx levels range from 0.3 to 0.8 ppm in the off-peak hours and from 1.3 to 3.2 in the peak hours. The
measured average daily PM10 concentrations are in between 29 and 153 μg/m3 and the measured
maximum daily concentrations range from 49 to 365 μg/m3. Some of the measured peak PM10 levels
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have been associated with the nighttime construction activities related to the tunnel leaks. The levels are
expected to get lower once the repair and construction process is finished.
To ensure compliance with the emission limits from any location, CEM emission action levels (i.e., 75 to
80% of the emission limit) have been established for each of these locations. Project operating
experience indicates that acceptable tunnel CO concentrations can be effectively maintained by step-wise
small increases in the ventilation rate.
Based on the Project’s already efficient ventilation design, in particular, the abundant available capacity
in the Project’s ventilation system, as concluded from recent operating experience and implementation of
the emission action levels, emission excursions are considered to be an unlikely event. Therefore,
specific information regarding the mitigation plan are not included as part of this Operating Certification.
However, should an excursion(s) in an emission limit(s) routinely occur because of normal traffic
conditions, and the steps outlined in the contingency plan become ineffective in eliminating the
excursion(s), and pursuant to 310 CMR 7.38(6) Mass DEP finds that one or more criteria set forth in 310
CMR 7.38 are being violated or likely to be violated, then MTA will develop and submit to the Mass
DEP, a mitigation plan as required under 310 CMR 7.38(6).
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Approximately 3.6 miles (or 80 lane miles) of these new roadways are underground tunnels, including the
7,900-foot-long, four-lane Ted Williams Tunnel (TWT) under the Boston Harbor that connects East
Boston to South Boston, the eight to ten lane underground Southeast Expressway (I-93), and the
underground portions of the Massachusetts Turnpike (I-90). The TWT was opened to commercial and
other authorized vehicles on December 15, 1995, and the entire Project was fully opened to general traffic
in March 2005.
In response to authorization from the FHWA in November 1995 regarding the use of the longitudinal
ventilation system, the Massachusetts Highway Department (MHD) implemented design refinements to
the Project's tunnel ventilation system by using jet fans as a potentially viable alternative for maintaining
adequate ventilation. Specifically, the refinements included the replacement of the full-transverse
ventilation systems with longitudinal ventilation at Dewey Square Tunnel (DST) section of I-93
Southbound, and at eight tunnel exit ramps.
The design followed the FHWA-Environmental Protection Agency (EPA) in-tunnel air quality criteria,
which were established based on time exposure of the motorists traveling inside the tunnel. Based on
these criteria; the tunnel operator is required to maintain CO levels below 120 part per million, when the
time exposure does not exceed 15 minutes during peak rush hour traffic, 65 ppm for exposure between
15 and 30 minutes, 45 ppm for 30 to 45 minutes, and 35 ppm when the motorists could remain 60 minutes
inside the tunnels. The estimated average time for a vehicle traveling inside the tunnel is less than
9 minutes during PM peak hour conditions and is shorter for AM peak hour conditions.
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From a tunnel ventilation perspective, the Project is best defined as three distinct and separate road tunnel
“systems”: the Ted Williams Tunnel, the I-90 Tunnel Extension and the I-93 Central Artery Tunnel.
Each of these tunnel systems has been divided into multiple “ventilation zones”. Each ventilation zone is
served by a dedicated and independently controlled set of fans. This concept allows for significant
operational flexibility throughout the Project and provides the means for establishing the most efficient
system operation under normal conditions and the most effective system operation in the case of a traffic
incident or fire emergency.
The tunnel ventilation system was designed with a supply air capacity of 65 cubic feet per minute (cfm)
per lane-foot of tunnel, and an exhaust capacity of 100 cfm per lane-foot of tunnel. The total supply
capacity for the full transverse ventilation system (including all six ventilation buildings [VBs]) is
approximately 11.4 million cfm serving the 22 ventilation zones. This ventilation system was designed
(15 years ago) to maintain in-tunnel CO levels between 20 and 60 ppm, and NOx levels between 1 and
5 ppm, during normal peak hour traffic conditions. Due to the advances in emission control technology
and the public’s demand for cleaner air, new car emissions are progressively decreasing. Therefore, the
CA/T Project ventilation system is expected to provide ample ventilation to accommodate the anticipated
traffic growth.
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The airflows for the full-transverse system are controlled by the many supply and exhaust fans. Airflows
are set from the ventilation control system located in the CA/T Project’s Operation Control Center (OCC)
in South Boston, and is determined by the CO levels monitored inside each ventilation zone.
This section provides a qualitative assessment of air quality conditions associated with the removal of the
aforementioned exhaust panels.
As designed, vehicular emissions inside the CA/T project tunnels are collected by the tunnel ventilation
system and exhausted into the plenum and then into atmosphere via exhaust stacks. There is no change in
emissions from vehicles traveling inside the affected portions of the tunnel sections and these emissions
are very small when compared to the total VB 5 emissions.
Because of eliminating 200 feet of the eastbound exhaust plenum, vehicle emissions generated inside this
tunnel portion will be carried forward directly into the open boat section between the I-90 Connector and
Ted Williams Tunnel by the air flow created by vehicles exiting the tunnel. The boat section is
approximately 35 feet below street level and most of these emissions will remain inside the boat section.
These emissions will either continue traveling farther into the eastbound entrance portal of the Ted
Williams Tunnel or will get re-circulated by westbound traffic back into the I-90 Connector. A small
portion of these emissions will also migrate up and out of the boat section. Emissions that are carried
forward into the eastbound Ted Williams Tunnel will be picked up by VB 6 and exhausted to the
atmosphere through its exhaust stacks. Those emissions that are drawn back into the I-90 Westbound
Connector will be exhausted through VB 5.
As discussed in Section 1.1, the project’s tunnel ventilation system has been adequately designed to
maintain safe in-tunnel air quality for motorists traveling through these tunnels. Subsequent Continuous
Emissions Monitoring (CEM) of carbon monoxide (CO) inside the project ventilation buildings and the
exit ramps, as reported in Section 5.5, validates the project ventilation system design. Based on nine
months of CEM data collected at VB-5 and VB-6 between October 2005 and June 2006, the maximum
observed hourly CO levels are well below 15% level of their respective allowable emission limits
presented in Section 2.6. During this period ventilation system needed to operate only at 25% of its fresh
air supply capacity level.
Because of the adequate fresh air supply and exhaust capacity of the project ventilation system, minimal
emissions shifting between VB 5 and 6 due to the I-90 Connector exhaust plenum modifications will
result in negligible changes to the CO levels at these ventilation buildings. Consequently, no significant
change to ambient air quality in the surrounding areas can be expected.
Some of these tunnel exit ramps are connected to the supply air from the VBs, and others have supply air
in the form of jet fans mounted inside the tunnel ceilings and walls. In all cases, these tunnels are self-
ventilated when the traffic flow moves at a speed that ranges from 20 to 45 miles per hour (MPH) (i.e.,
the traffic movement provides the majority or totality of the ventilation air). In the cases of traffic
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congestion, stalled conditions or incidents, the mechanical ventilation (supply air and/or jet fans)
supplements and/or replaces the natural self-ventilation system.
The fans that assist the longitudinal ventilation airflows are also controlled from the CA/T Project’s OCC
in South Boston, and they are manually operated according to the CO levels monitored inside each
section of these tunnels.
The newly reconstructed tunnel (which is connected at its northern end to the new CA/T I-93 southbound
tunnel) includes an Air Intake Structure (AIS) housing two centrifugal fans (300 horsepower (hp) and
300,000 cfm each). The AIS located above the DST alignment slightly south of Congress Street to
provide supply air in cases of roadway accidents or stalled traffic conditions.
In addition, in order to provide operator flexibility with respect to air flow management for normal and
emergency operations, three of the four existing DST fan chambers and shafts were retained and
rehabilitated with reversible axial fans which typically operate in the supply mode. In the instance of a
fire condition, these eight reversible fans (100 hp and 100,000 cfm each) will be operated in exhaust
mode to prevent “back layering” (movement of the hot air and combustion gases counter to the desired
direction of flow) of the smoke, protecting vehicles and passengers stopped behind the incident location.
The current DST exit portal is located 100 feet south of Kneeland Street (Figure 1-11). The future
location of the portal under the full commercial development scenario will be an additional 300 feet
further south, on the South side of the South Station Connector (also identified in Figure 1-11).
1.1.2.2 Exit Ramps with Fresh-Air Supply and/or Jet Fan Ventilation
There are eight longitudinally ventilated ramps, of which three include supply air and jet fan ventilation,
and the other five (which are not connected to the mainline tunnels) only include jet fans.
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NMHC refers to any hydrocarbon species other than methane and, for the purpose of characterizing the
ozone forming potential of organic emissions from automobiles, is used interchangeably with volatile
organic compounds (VOC) and non-methane organic gases (NMOG). The term VOC is used in this
document.
The tunnel ventilation systems introduce and circulate fresh ambient air into the tunnels, and remove the
mixture of vehicular exhaust and intake air from the tunnels through the exhaust stacks.
Ventilation building (VB) emissions control technology reviews were performed in 1991, 1995 and
subsequently updated in 2004. An extensive investigation, conducted as part of these reviews revealed
that ventilation was the predominant method of tunnel (inside and outside) air quality control employed in
the U.S. and around the world. All three studies concluded that there were no feasible control techniques
available that would result in a net reduction of the tunnel exhaust air pollutant emissions.
The use of electrostatic precipitator systems (ESPs) has been proven to be an effective method for
controlling particulate emissions, especially for long tunnels that have relatively high in-tunnel particulate
concentrations. Roadway tunnels equipped with ESPs in Europe and Japan are mostly those that are
relatively long and have poor in-tunnel visibility caused by heavy-duty diesel truck traffic (i.e., large PM
emission sources). By comparison, the CA/T tunnels are relatively short and have a lower volume of
diesel truck traffic. Therefore, the installation of ESPs for the CA/T Project probably would not result in
significant decreases in PM concentrations in the tunnel exhaust air.
Several methods of controlling gaseous emissions from tunnel exhausts are in various stages of
development. However, these methods have not yet been tested or applied to situations with very low
concentration levels such as in the exhaust air of the CA/T tunnels. The extremely high flow and the very
low concentration levels of pollutants in the exhaust air proved to be the two greatest impediments to the
practical application of these control techniques. Low concentrations and large flow rates would have
necessitated unreasonably large control equipment sizes, long treatment times, and the use of large
quantities of reagents and catalysts with the consequent generation of large amounts of waste and the need
for its disposal. More importantly, the energy (heat and power) requirements of the control techniques
would have resulted in fuel consumption and additional emissions of criteria pollutants (e.g., CO, NOx,
PM, SO2) and non-criteria pollutants (e.g., SO3, greenhouse gases such as CO2) that far exceed the
original uncontrolled emission rates due to vehicle exhausts alone.
In addition, the emission data collected inside the CA/T tunnel (and summarized in this report) indicates
that safe in-tunnel air quality has been well maintained. Likewise, the mathematical and physical
modeling conducted for this project has demonstrated that the applicable ambient air quality standards
will be met using the current ventilation system design.
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The system at each ventilation zone is normally operated in what is called a balanced mode; equal amount
of supply and exhaust air to keep the system in a neutral pressure. Only in the case of emergencies will
the system be operated in an unbalanced condition (i.e., over exhaust mode).
The ventilation control CO monitoring system is operated independent of the CEM system described in
Part II of this document. The CEM system is used to monitor compliance with the ambient air quality
standards while CO monitoring system is used to operate the ventilation fans, and it does not log
historical CO levels.
Real time values from each CO monitor are averaged by the OCC central computer system and reported
on a per ventilation zone basis. Any exceedance of preset alert levels within a ventilation zone triggers an
audible alarm to the operator and a banner display on the monitoring console provides specific data as to
actual concentrations, trend and location. When controlled manually, the operator is then able to make
any necessary adjustments to the ventilation zones in that particular tunnel area to restore safe air quality
to the tunnel. Ventilation system adjustments might also be made during normal traffic operation when
necessary to restore visibility that may be degraded due to heavy fog or dust conditions.
During these fire emergency situations it is MTA understanding based on discussions with Mass DEP that
the 310CMR 7.38(2)(a) and (b) criteria would not apply based on a need to protect public safety.
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As stated in Section 1.2, the tunnel ventilation system was designed with a supply air capacity of 65 cfm
per lane-foot of tunnel, and an exhaust capacity of 100 cfm per lane-foot of tunnel. The variable speed
fans can be operated at different steps (depending on the level of air flow delivered). The supply fans
vary from step 1 to 6, and the exhaust fans from step 1 to 8. This means that only steps 1 to 6 are required
to operate the system in a balanced mode (supply equals exhaust), while steps 7 and 8 are used in cases of
emergency and fire conditions. Table 1-2 provides the total exhaust capacity of each ventilation zone and
the same capacity at each operating step. Figure 1-18 provides a view of a supply fan at VB 7 with the
CO and PM10 monitoring unit.
CO and PM10
Monitoring Enclosure
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The dimensions, number of lanes and mechanical ventilation capacities of the DST and the eight
longitudinally ventilated ramps exit portals are provided in Table 1-3. Figure 1-19 provides a view of a
side-mounted jet fan.
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No Ramps/Scenario Length (ft) of Lanes Length (lane-ft) Supply Air Min Jet Fan Max Jet Fan
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The air flows at the exit portals are very dependant of the traffic characteristics such as vehicle
classification, density and speed at any given time.
In order to provide an indication of the airflows generated by the traffic flows and the available
mechanical ventilation that can be delivered by the air supply and jet fans, Table 1-14 summarizes the air
flows at each portal as they have been estimated in support of the air quality evaluation for the Notice of
Project Change (NPC)/Environmental Reevaluation (ER) for the Implementation of Longitudinal
Ventilation in the Area North of Causeway Street and Central Area, October 1996 (1996 Longitudinal
Ventilation NPC/ER), and the DST final report Air Quality Study Dewey Square Portal Boston,
Massachusetts, prepared by RWDI, January 2006.
TABLE 1-4: TRAFFIC VOLUMES, SPEEDS AND AIR FLOW RATES FOR DST AND EIGHT
LONGITUDINALLY VENTILATED RAMPS
The conditions analyzed in the wind tunnel tests include the partial and full development conditions. The
DST airflows provided represent a combination of traffic induced piston effect and the AIS operating at
50% capacity. The ramps airflows are only the result of piston action. It is worth noting the differences
in the airflows between the peak and eight hour scenarios and the effect of the traffic speeds on such
airflows.
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On February 20, 1991, to comply with the provisions of the Vent Cert Regulation, the Massachusetts
Department of Public Works, now the MHD submitted to Mass DEP a Pre-Construction Certification of
the Tunnel Ventilation System for the CA/T Project (Pre-Construction Certification). The Pre-
Construction Certification was found to be administratively complete by Mass DEP on March 27, 1991.
On May 7, 1991, Mass DEP conducted a public hearing on the Pre-Construction Certification to receive
comments pursuant to 310 CMR 7.38(11). After review of the information set forth in the Pre-
Construction Certification and consideration of information presented at the public hearing and during the
public comment process, Mass DEP accepted the Pre-Construction Certification subject to conditions set
forth in the decision document dated July 8, 1991 entitled Conditional Acceptance of Pre-Construction
Certification of the Central Artery/Third Harbor Tunnel Project (Conditional Acceptance). Mass DEP
determined that the mitigation measures set forth in the Conditional Acceptance were necessary to
mitigate potential adverse air quality impacts from the CA/T Project and to meet the criteria set forth in
the Vent Cert Regulation for project certification. The mitigation measures set forth in the Conditional
Acceptance included Public Transportation Measures, Measures to Increase Commuter Rail Ridership,
Water Transportation Measures, Transportation Management Measures and a High Occupancy Vehicle
(HOV) Program.
On September 10, 1992 MHD submitted an amendment to the Pre-Construction Certification to update
technical information based on design refinements to the CA/T Project and to provide a basis for Mass
DEP to clarify the requirements of Section VI of the 1991 Technical Support Document, (that was
submitted with and in support of the Pre-Construction Certification) to provide consistency with the 1991
Transit Regulations, 310 CMR 7.36, and HOV Regulations, 310 CMR 7.37, that were adopted by Mass
DEP in December 1991.
On January 7, 1999 the MTA, on behalf of MHD, submitted to Mass DEP for its review and acceptance
pursuant to the Vent Cert Regulation an amendment to the Pre-Construction Certification. The 1999
Amendment to the Pre-Construction (Amended Pre-Construction Certification) superseded the 1992
amendment. Submitted with and in support of the Amended Pre-Construction Certification was a 1999
Technical Support Document that updated, (but did not replace), the 1991 Technical Support Document
to reflect analyses performed in connection with design changes to the CA/T Project since 1991 that had
been reviewed through the Massachusetts Environmental Policy Act (MEPA) and that had then been
incorporated as part of the CA/T Project design. In addition, the 1999 Technical Support Document
updated Section VI, of the 1991 Technical Support Document on “Methods to Minimize Miles Traveled”
to reflect the current status of the demand reduction strategies and transportation control measures
included in the planning and implementation programs of the Executive Office of Transportation and
Construction (EOTC), now Executive Office of Transportation (EOT).
The Amended Pre-Construction Certification was found to be administratively complete by Mass DEP on
February 26, 1999. On March 30, 1999 Mass DEP conducted a public hearing on the Amended Pre-
Construction Certification to receive comments pursuant to 310 CMR 7.38(11). Mass DEP issued
proposed decision documents on the Amended Pre-Construction Certification on April 29, 1999 and
conducted a public hearing on those proposed decisions on May 20, 1999. After review of the
information submitted by MTA, MHD and EOTC and the information presented at the public hearings
and during the public comment period, Mass DEP accepted the Amended Pre-Construction Certification
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subject to certain conditions in a document dated September 1, 2000 entitled “DEP Determination on the
Amended Pre-Construction Certification of the CA/T Project under 310 CMR 7.38” (DEP
Determination). Among those conditions was an Administrative Consent Order (ACO) by and between
Mass DEP and EOTC, also dated September 1, 2000 that was incorporated by reference into and thereby
made part of the Mass DEP Determination. The ACO has been twice amended; Amendment #1 on May
23, 2002 and Amendment #2 on January 26, 2005.
The Pre-Construction Certification and the Amended Pre-Construction Certification required a number of
mitigation measures designed to “ ... mitigate potential adverse air quality impacts from the CA/T Project
and to meet the criteria for project certification.” To address delays in certain mitigation measures, the
ACO and amendments to the ACO required additional measures to be implemented to provide reductions
in vehicles miles traveled and emissions during the delay of the required mitigation measure.
MTA should also demonstrate that the operation of the tunnel ventilation system is in accordance with the
criteria set forth in the Pre-Construction Certification accepted by Mass DEP. The Ventilation
Certification Regulation provides that this demonstration shall be based on actual measured emissions and
traffic data.
It is worth noting that based on discussion with Mass DEP it is MTA understanding that the 310 CMR
7.38(2) requirements regarding compliance with the applicable ambient air quality standards and the State
Policy guideline for nitrogen dioxide would not apply during emergency conditions (i.e., tunnel fires).
In support of the Operating Certification, an air quality compliance demonstration was performed.
However, MTA is required to establish emission limits for the tunnel ventilation system such that
operation of the CA/T ventilation system below these limits would not cause or exacerbate a violation of
any applicable ambient standards. Actual CA/T operating experience and measured in-tunnel pollutant
concentration levels thus far are taken into consideration in determining these emission limits.
During the past five years, a technical working group representing the CA/T Project and Mass DEP, have
been meeting on a quarterly basis to discuss the methodologies for determination of the CA/T tunnel
ventilation system emission limits, continuous emission monitoring and demonstration of ambient air
quality compliance.
The Project Compliance Monitoring Program during operation includes CO continuous emission
monitoring at the plenum of each ventilation zone, and PM10 continuous emission monitoring at four
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ventilation zones which represents the ventilation zones with the largest potential for high PM10 levels at
the mainline tunnel exhaust points. Due to the limited space available and other technical impediments
inside the ramps, instead of in-tunnel monitoring it was agreed with Mass DEP that a permanent PM10
monitor will be installed outside exit Ramp CS-SA to determine if the emissions from the longitudinally
ventilated ramps could have the potential to cause high PM10 levels in the adjacent areas. NOx levels at
each CEM monitoring location will be determined as a function of the hourly monitored CO levels. The
monitoring results and the calculated NOx levels are compared to their predetermined emission limits for
compliance assessment.
For the volatile organic pollutants (VOC) the MTA is required to demonstrate that the tunnel ventilation
system when operated in accordance with its design, standard operation, and maintenance procedures
would not result in an actual or projected increase in the total amount of VOC measured within the
Project area compared to the No-Build alternative. The 2005 regional VOC emissions for the area
affected by the CA/T Project Build scenarios are compared to the No-Build scenario (budget) and will
then be used as a limit, which is not to be exceeded in the future years for compliance demonstration
purposes.
Vehicular emissions depend on the number, type and conditions of the vehicles and their traveling speeds.
Although the MTA is the Owner and Operator of the CA/T tunnel ventilation system, the Project tunnels
are open for general public use under normal operation conditions without exception. Therefore, the
MTA has no control regarding the type and conditions of vehicles entering the tunnel and it can only
manipulate the ventilation rates of the tunnel ventilation system based on traffic conditions to provide
acceptable in-tunnel air for the motorists traveling the tunnels. Thus, the emission limits to be set for all
three pollutants will be the maximum allowable concentrations which will ensure that the applicable
ambient standards are not exceeded.
Since there are no NAAQS for VOC, emission limits for VOC cannot be established based on
concentrations to be measured at a specific receptor location. As such, direct measurement or monitoring
of VOC without a benchmark level to guide the operation of the ventilation system may or may not
contribute to the protection of the health and welfare of the affected population. A different procedure
that is based on the study area VOC budget was developed by the MTA-Mass DEP air quality working
group and accepted by Mass DEP on July 30, 2002. The established VOC budget for the CA/T Build
condition will then be used as the emission limit, which is not to be exceeded in the future years for
compliance demonstration purposes.
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2.4.2 Time Averaging Emission Limit for CO, NOx, and PM10
The duration of the emission limits for CO, PM10, and NOx are determined by their respective NAAQS
and Mass DEP Policy Guideline Value as follows:
Duration Pollutant Emission Locations
1-hour and 8-hour CO VB exhaust plenum and longitudinally ventilated ramps
1-hour NOx VB exhaust plenum and longitudinally ventilated ramps
24-hour PM10 VB exhaust plenum and vicinity of Ramp CS-SA
The 1997/98 TWT Emissions Monitoring Program measured CO, NO, NOx, total hydrocarbons (THC),
and PM10 for a two week period every quarter from December 1996 thru December 1998 at four
ventilation zones for VB 7 and two ventilation zones for VB 6. The results of more than 20,000 hourly
values recorded indicated that there was a good correlation between measured levels of NO, NOx and CO.
Correlation coefficients were between 0.5 and 0.82, and linear regression models were developed to
predict in-tunnel NO and NOx levels based on measured CO levels.
At the request of Mass DEP, these regression models were refined by collecting additional data when I-90
opened for general public use to account for the difference in vehicle classification from the Early
Opening Phase, and to represent the Full Opening traffic conditions.
During 2003, the MTA and Mass DEP technical working group agreed that the CO/NOx relationship (or
regression model) was to be used for the prediction of NOx levels for emission limit determination and for
demonstration of compliance with the Mass DEP one-hour NO2 policy guideline (320 μg/m3) as it relates
to 310 CMR 7.38. The 2004 TWT monitoring program collected an additional two weeks of CO, NOx
and NO hourly data at all four ventilation zones of VB 7 every quarter (approximately 6,000 hours of
measurements).
Since the 2004 monitoring data reflects the current TWT operating conditions (general traffic use and
recent vehicle technology), the regression models based on the 2004 data were chosen to represent current
full traffic conditions. Also, since the ambient O3 levels are higher during summer, regression formula
based on the 2004 summer data for NOx predictions was chosen for compliance demonstration.
The CO and NOx data collected during August 9-25, 2004 are plotted in Figure 2-1. The equation
developed from this data set to be used in the modeling analysis and to estimate the hourly NOx levels is:
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CO 10.0 15.0 20.0 25.0 30.0 35.0 40.0 45.0 50.0 55.0 60.0 65.0 70.0
NOx 1.44 2.06 2.68 3.30 3.92 4.54 5.16 5.78 6.40 7.02 7.64 8.26 8.88
The report titled CA/T Ted Williams Tunnel 2004 Carbon Monoxide – Nitrogen Oxides Monitoring
Program, December 2004, includes full description of the data collection process and statistical analysis.
The report was submitted to Mass DEP on January 13, 2005; and Mass DEP agreed to the use of the
above equation for the compliance demonstration (Mass DEP letter March 24, 2005).
2.5
2
NOx
1.5
Rp=0.837
0.5
0
0 2 4 6 8 10 12 14 16 18 20
CO
The amount of NO2 present in the atmosphere within the CA/T Project impacted areas is a combination of
three different sources of NO2:
• NO2 directly emitted from the vehicles and released into the atmosphere through the VB and the exit
portals.
• NO2 formed from the oxidation of NO that is emitted from the vehicles and released into the
atmosphere through the VBs and the exit portals.
• NO2 present as background in the atmosphere.
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The Ozone Limiting Method (OLM) that is used assumes that the reaction of NO with O3 is the
predominant pathway for conversion of NO to NO2. For the CA/T Project, an upper limit of 81%
conversion of NO to NO2 was established in the 1990 FSEIS/R analysis, and it has been used on all CA/T
air quality modeling analyses. This maximum limit includes 76% NO to NO2 conversion, and 5% of the
vehicular NOx emitted directly as NO2.
The total amount of NO2 estimated at each receptor location will be calculated as follows:
For 0.81 [NOx] > [O3], [NO2] = 0.05 [NOx] + [O3] + [NO2] background (2)
For 0.81 [NOx] < [O3], [NO2] = 0.05 [NOx] + 0.76 [NOx] + [NO2] background (3)
For the longitudinal ventilation analysis CO background levels are the years 2000 to 2004 hourly
measurements at the Mass DEP Roxbury monitor at Back Bay at Harrison Avenue. For full transverse
ventilation a highest second highest one hour and eight hour average concentrations from the latest three
years were selected as shown in Table 2-2. The CO levels of 2.8 ppm for one-hour and 2.4 ppm for eight
hours were used in the modeling.
The NO2 background concentrations for compliance with the Mass DEP Guidance level are comprised of
the year 2000 hourly data collected at the Mass DEP Bremen Street monitor in East Boston and of years
2001 to 2004 hourly data collected at the Mass DEP Harrison Avenue monitor at Back Bay. Monitoring
of the NO2 concentration at Bremen Street was discontinued by Mass DEP in 2001. The required
concurrent five years of hourly O3 data were collected also at the Harrison Avenue Mass DEP monitoring
station. The annual NO2 background concentration was the highest of the latest three year annual
averages as presented in Table 2-3.
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PM10 background concentrations are based on data recorded for the last three years (i.e., 2002–2004) at
the TEOM® station located in North End.
Table 2-4
24-hours
Year Total Days 1st Highest 2nd Highest 3rd Highest Annual Average
2002 208 87.6 77.5 60.6 24.0
2003 344 59 46.3 45.8 21.8
2004 288 57 54.8 47.5 22.1
Summary 840 87.6 77.5 60.6 22.6
The 24-hour background level is selected based on the total number of observations for the three years.
For years 2002 through 2004 at the North End monitoring station the 24-hour background should be the
third highest observation of the three year period—60.6 μg/m3. The annual background is the annual
average of the three years—22.6 μg/m3. This follows the procedures in the EPA PM10 SIP Development
Guideline (EPA-450-2-86-001). The North End station had 840 observations between 2002 and 2004.
The use of the third highest is recommended by EPA if the number of observations is between 696 and
1042 (see Table 2-4).
This process mirrors the process used in the 1990 FSEIS/R for the Preconstruction Certification, but it is
based on current traffic and motor vehicle emission data instead of future projections of the Project effects
on a distant future. As such it will provide a much higher level of confidence on the actual area wide
effects of the CA/T Project including transit commitments which form part of the Ventilation System
Certification Process.
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The maximum hourly allowable emission limits (in ppm) for the VBs, DST and the specified exit ramps
are determined using an iterative modeling process by increasing or decreasing the exhaust concentration
in a prescribed interval.
In principle, the final emission limits are expected to be set as high as the maximum allowable levels such
that when the CA/T ventilation system exhaust concentration is below this limit, it will not cause or
exacerbate a violation of the applicable NAAQS and at the same time allow for traffic growth in the
Project tunnels and also provide flexibility in operating the tunnel ventilation system.
As discussed in Section 1, there are a total of 22 ventilation zones in the CA/T ventilation system. In
general each of these ventilation zones is equipped with more than one exhaust stack and each stack is
dedicated to serving one exhaust fan. Fan speeds are controlled by 8 set point steps.
In the modeling, all stacks serving one ventilation zone are group together and treated as an individual
emission point. The physical center of the stacks serving the same ventilation zone is treated as the center
of the source in the modeling runs. The total stack exit area is used in calculation of the equivalent stack
diameter. The total flow rate is divided by the total stack exit area to obtain the equivalent stack exit
velocity. A spectrum of four ventilation scenarios (based on fan steps 2, 3, 4 and 5) were selected to be
modeled.
The highest predicted pollutant concentration is added to the appropriate background level to estimate
their combined impact and to compare to the applicable short or long-term air quality standard.
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To facilitate the selection of an initial exhaust concentration level to begin the iterative process, computer
test runs were made to compare the resulting impacts of different ventilation scenarios (i.e., at fan steps 2,
3 and 4). Modeling results indicate that for a given exhaust concentration level the higher the exhaust rate
becomes, the worst the impact gets. Therefore, the worse impact would be associated with the highest
ventilation scenario.
Initially a spectrum of four ventilation scenarios (based on fan steps 2, 3, 4 and 5) were selected to be
modeled. Based on past CA/T Project-specific operating experience, operating the tunnel at in-tunnel CO
level of 70 ppm in combination with fan speed at Step 5 is a very unlikely event. Therefore, a detailed
impact assessment associated with such an operating scenario is not considered
For each ventilation zone, the exhaust capacity by fan step can be found in Table 1-2. Model input data,
including emission rates, exhaust flow rates, exhaust temperature, and number of fans by ventilation zone
are presented in Table 2-7. The stack locations and configurations for all the VBs are depicted in Figures
2-2 through 2-7. Representative stack locations and sensitive receptors used in the modeling analysis are
presented in Appendix C, “Air Quality Impact Analysis Input Data” (Tables C-3 through C-8) for each
VB. Background air quality levels used in the analysis are described in Section 2.4.8.
CO Analysis
As a starting point, the exhaust CO concentration at each emission point was arbitrarily set at a much
higher level (70 ppm) than the current tunnel operating conditions (20–30 ppm) to facilitate the
identification of the maximum hourly allowable emission limits. This hypothetical high in-tunnel CO
concentration in combination with the proposed Fan Step 4, which is equivalent to an exhaust flow rate at
42% of the total exhaust capacity, form the basis for the initial compliance test case. Results of the
analysis for all VBs, as reported in Tables 2-5 and 2-6, indicate that the maximum combined impacts at
receptor locations resulting from operation of each of the VBs are less than 60% of the NAAQS for CO.
It is worth noting that the predictions for both the 1-hour and 8-hour averaged CO levels at all receptors
are based on the selected hourly emission level of 70 ppm.
Year Highest
VB 2000 2001 2002 2003 2004 Concentration
VB 1 8.9 9.6 9.8 9.4 8.6 9.8
VB 3 11.6 14.5 9.9 13.6 13.9 14.5
VB 4 8.0 7.8 7.7 8.3 7.4 8.3
VB 5 6.5 6.7 6.4 6.5 6.6 6.7
VB 6 5.1 5.1 5.1 5.1 5.1 5.1
VB 7 7.6 7.6 7.6 7.8 7.6 7.8
Note: One hour CO NAAQS is 35 ppm; source strength is 70 ppm.
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Vent Building 4
Exhaust % Flow CO Total Mass Mass Flow Area of Total Exit Equ. NOx NOx NOx NOx
Vent # of Capacity/ Capacity Step Capacity Rate PPM Molecular Density CFM Flow CO CO/Stack a single Exit Vel. Dia. Conc. Molecul Conc. Emis.
2 2
Bldg Zone Fans Fan (CFM) (CFM) Used Used (CFM) CO Weigt CO (lb/ft^3) CO (g/sec) (g/sec) cell (ft ) Area (ft ) (m/s) (m) (ppm)* ar Wt** (ug/m3) (g/s)
4 SB-2 4 237250 949000 4 0.42 398580 70 28 0.07238 27.90 15.27 3.82 106.6 426.4 4.75 7.10 8.876 30.8 11181.3 2.10
4 SB-3 4 282625 1130500 4 0.42 474810 70 28 0.07238 33.24 18.19 4.55 106.6 426.4 5.66 7.10 8.876 30.8 11181.3 2.50
4 NB-3 4 221250 885000 4 0.42 371700 70 28 0.07238 26.02 14.24 3.56 106.6 426.4 4.43 7.10 8.876 30.8 11181.3 1.96
4 NB-4 4 202250 809000 4 0.42 339780 70 28 0.07238 23.78 13.01 3.25 106.6 426.4 4.05 7.10 8.876 30.8 11181.3 1.79
Vent Building 5
Exhaust % Flow CO Total Mass Mass Flow Area of Total Exit Equ. NOx NOx NOx NOx
Vent # of Capacity/ Capacity Step Capacity Rate PPM Molecular Density CFM Flow CO CO/Stack a single Exit Vel. Dia. Conc. Molecul Conc. Emis.
2 2
Bldg Zone Fans Fan (CFM) (CFM) Used Used (CFM) CO Weigt CO (lb/ft^3) CO (g/sec) (g/sec) cell (ft ) Area (ft ) (m/s) (m) (ppm)* ar Wt** (ug/m3) (g/s)
5 SAT-WB-E2 4 260000 1040000 4 0.42 436800 70 28 0.07238 30.58 16.73 4.18 106.6 426.4 5.20 7.10 8.876 30.8 11181.3 2.30
5 SAT-WB-E3 2 196500 393000 4 0.42 165060 70 28 0.07238 11.55 6.32 3.16 106.6 213.2 3.93 5.02 8.876 30.8 11181.3 0.87
5 SAT-EB-E2 4 278000 1112000 4 0.42 467040 70 28 0.07238 32.69 17.89 4.47 106.6 426.4 5.56 7.10 8.876 30.8 11181.3 2.46
5 SAT-EB-E3 2 279000 558000 4 0.42 234360 70 28 0.07238 16.41 8.98 4.49 106.6 213.2 5.58 5.02 8.876 30.8 11181.3 1.24
Vent Building 7
Exhaust % Flow CO Total Mass Mass Flow Area of Total Exit Equ. NOx NOx NOx NOx
Vent # of Capacity/ Capacity Step Capacity Rate PPM Molecular Density CFM Flow CO CO/Stack a single Exit Vel. Dia. Conc. Molecul Conc. Emis.
Bldg Zone Fans Fan (CFM) (CFM) Used Used (CFM) CO Weigt CO (lb/ft^3) CO (g/sec) (g/sec) cell (ft2) Area (ft2) (m/s) (m) (ppm)* ar Wt** (ug/m3) (g/s)
7 Eastbound Zone 2 3 274000 822000 4 0.42 345240 70 28 0.07238 24.17 13.22 4.41 106.6 319.8 5.48 6.15 8.876 30.8 11181.3 1.82
7 Westbound Zone 2 3 231000 693000 4 0.42 291060 70 28 0.07238 20.37 11.15 3.72 106.6 319.8 4.62 6.15 8.876 30.8 11181.3 1.54
7 Eastbound Zone 3 2 226000 452000 4 0.42 189840 70 28 0.07238 13.29 7.27 3.64 106.6 213.2 4.52 5.02 8.876 30.8 11181.3 1.00
7 Westbound Zone 3 3 203000 609000 4 0.42 255780 70 28 0.07238 17.90 9.80 3.27 106.6 319.8 4.06 6.15 8.876 30.8 11181.3 1.35
7 T-A/D 3 194333 583000 4 0.42 244860 70 28 0.07238 17.14 9.38 3.13 106.6 319.8 3.89 6.15 8.876 30.8 11181.3 1.29
Notes:
1. Assumes all fans in a given zone are operating simultaneously.
2. Higher bound assumed conditions represent 70 ppm CO and Step 4 (a high ventilation rate for modeling purpose).
* NOx (ppm) = 0.196 + 0.124CO (ppm)
** NOx molecular weight assumed for 95% NO and 5% NO2
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Based on these modeling results, no further CO impact analysis iterations were performed.
NO2 Analysis
The NO2 in-tunnel concentration was estimated using the Project-specific regression model as follows:
For CO at 70 ppm, the equivalent in-tunnel NOx concentration would be 8.88 ppm.
By following the similar modeling process used in the CO analysis, the NOx concentration levels
contributed by the VBs at all receptors were calculated using the ISC model. For air quality compliance
demonstration purpose, these NOx concentration levels will need to be converted into NO2 because the
applicable ambient air quality standard and the Mass DEP Policy Guideline Value are set for NO2, not
NOx.
Since most of the NOx emitted by vehicles is mostly in the form of NO and the reaction of NO with O3 is
the predominant pathway for conversion of NO to NO2, the final calculation of NO2 was carried out by
applying the Ozone Limiting Method (OLM). The resultant hourly NO2 concentrations derived from the
OLM were summarized in Table 2-8. As shown in the table, the maximum hourly NO2 concentration of
0.16ppm (296.6 µg/m3), which is the highest among all VBs was predicted for VB7. This maximum
concentration is below the Mass DEP Policy Guideline value 0.17ppm (320 µg/m3) for NO2.
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For compliance demonstration with the NO2 annual NAAQS, a realistic annual average NOx emission rate
was used instead of the maximum hourly NOx emission rate to determine the air quality impacts. The
reduction factor for adjusting the maximum hourly emission rate to an annual average value was derived
from five months of CO measurements made inside the DST along the I-93 Mainline and the I-90
Collector during 2005 in conjunction with the use of the Project-specific regression formulation that
calculates NOx based on the CO measurements. Analysis of the CO monitoring data indicated that the
ratio of the 5-month average hourly value to the highest recorded hourly CO value is 0.23. The
corresponding reduction factor for NOx was calculated to be 0.25. Finally, a conservative conversion
factor of 75% on an annual basis was further applied to the annual NOx results for converting NOx to NO2
as suggested by the EPA (EPA, 91-180.6).
Results of the maximum annual NO2 impacts for all VBs are summarized in Table 2-9. The maximum
predicted annual NO2 concentration, including the appropriate background, is 0.03 ppm (61 µg/m3),
which is well below the annual NO2 NAAQS of 0.05 ppm.
Year Highest
VB 2000 2001 2002 2003 2004 Concentration
VB 1 0.026 0.026 0.026 0.026 0.025 0.026
VB 3 0.024 0.025 0.024 0.025 0.025 0.025
VB 4 0.024 0.024 0.024 0.024 0.025 0.025
VB 5 0.028 0.028 0.028 0.028 0.028 0.028
VB 6 0.025 0.025 0.025 0.025 0.024 0.025
VB 7 0.031 0.030 0.030 0.029 0.030 0.031
Notes: Annual NO2 NAAQS is 0.05 ppm. Background NO2 is 0.023 ppm.
Based on these modeling results, no further NO2 impact analysis iterations were performed.
PM10 Analysis
Similarly, the PM10 emission limits for the VBs were identified by starting the modeling process at an
assumed concentration (500 μg/m3). The 500 μg/m3 is the worst case that was selected based on the
levels measured in tunnels. Note that this assumed hourly PM10 emission level was used for both the
24-hour and annual average predictions.
The 24-hour and annual modeling results for all VBs are presented in Tables 2-10 and 2-11, respectively.
When added to the appropriate background PM10 levels, the maximum 24-hour impact was 73 µg/m3 and
the maximum annual impact was 26.1 µg/m3. Both these maximums are caused by emissions from VB 7
and they are well below the annual and 24-hour NAAQS values of 50 µg/m3 and 150 µg/m3, respectively.
Year Highest
VB 2000 2001 2002 2003 2004 Concentration
VB 1 68.5 69.8 68.2 68.9 68.7 69.8
VB 3 65.4 68.3 63.9 66.9 65.3 68.3
VB 4 66.3 66.6 65.6 67.9 66.0 67.9
VB 5 69.0 70.3 69.7 68.0 68.0 70.3
VB 6 66.1 66.0 65.5 65.7 66.2 66.2
VB 7 72.4 73.0 72.5 72.6 72.0 73.0
Notes: 24-hour PM10 NAAQS is 150 μg/m3 Background PM10 level is 60.6 μg/m3
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Year Highest
VB 2000 2001 2002 2003 2004 Concentration
VB 1 24.0 24.1 24.0 24.0 23.8 24.1
VB 3 23.3 23.4 23.3 23.4 23.4 23.4
VB 4 23.2 23.3 23.1 23.3 23.3 23.3
VB 5 24.9 24.8 24.8 24.8 24.8 24.9
VB 6 23.5 23.5 23.6 23.5 23.4 23.6
VB 7 26.1 25.9 25.9 25.6 25.9 26.1
Note2: Annual PM10 NAAQS is 50 μg/m3 Background PM10 level is 22.6 μg/m3
Based on these modeling results, no further PM10 impact analysis iterations were performed.
The changes analyzed in the 1996 Longitudinal Ventilation NPC/ER were the direct results of the
emissions that previously were vented through the exhaust stacks of VB 8 (eliminated with longitudinal
ventilation), and that now are exhausted through the exit portals of ramps CN-S and L-CS. Another
change included a small portion of emissions that previously were vented through VBs 3 and 4, and is
currently vented through the exit portals of the ramps SA-CN, ST-CN, ST-SA, CS-SA and CS-P.
Another physical simulation study was performed for Ramp F as part of the air quality evaluation for the
Notice of Project Change (NPC)/Environmental Reevaluation (ER) for the South Bay/South Boston
Areas. In order to simplify the ducting system for VB 5, the ventilation of exit ramp F was removed from
VB 5 and exit ramp F is longitudinally ventilated by the piston action of the vehicles with the addition of
jet fans exhausting the air through its exit portal during emergency conditions.
In order to replicate the effects of the air flows created by the moving traffic at these exit ramps, six 1:100
and 1:200 scale models were built at the RWDI wind tunnel testing facility in Guelph, Ontario.
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Each model included the individual ramps, and its surrounding buildings within 800 to 1,600 feet from
each portal. The scenarios with and without the development of parcels 6 and 12 were also studied. The
effects of the moving vehicles were simulated using moving belts, with attached semi spheres
representing the aerodynamic characteristics of the predicted traffic speed and density. The model scale
vehicle drag took into account the modeled vehicles and the conveyor belt itself.
Flow visualization tests were initially performed to determine the most likely location of the highest
impacts, and detailed tracer gas tests were performed at the identified high impact locations, including
sensitive public areas, and air intakes of the surrounding buildings. Tracer gas tests were performed at the
wind tunnel facility for each ramp, at each specified traffic and parcel development scenario. The tracer
gas concentration measured at each receptor location was recorded as a percentage of the gas
concentration measured at the exit portal (this data provides what can be described as a dilution ratio for
each location).
A full description of the study methodology and results was prepared in the report Physical Simulation
Study for the Implementation of Longitudinal Ventilation Systems in the Area North of Causeway and
Central Area, by RWDI, October 1996. The report was submitted to Mass DEP as part of the 1996
Longitudinal Ventilation NPC/ER.
The detailed modeling procedures used for determination of the longitudinal ventilation emission impacts
and emission limits can be found in Appendix B, “Air Quality Analysis Protocol for Determination of
Emission Limits as Part of the Operating Certification of the Project Ventilation Systems” of this
document.
The objective of the 2005 exhaust dispersion study was to evaluate different Build scenarios (from No-
Build to fully developed Parcels 24, 25 and 26a), and how these scenarios would affect the dispersion of
exhaust from the two vehicle tunnel portals located south of Kneeland Street. These two portals carry the
I-93 south-bound mainline traffic (CASB), and the I-90 collector traffic (Ramp H/Slip Ramp). The
sources included in this assessment were the exhausts from the CASB and Ramp H/Slip Ramp exit
portals. Three physical configurations evaluated included:
• Configuration 1 – the relocated CASB portal (400 feet south of Kneeland Street) with development at
Parcels 24, 25 and 26a (Figure 2-15)
• Configuration 2 – the existing CASB portal location with development at Parcels 24 and 26a and low
existing retaining wall (Figure 2-16)
• Configuration 3A – the existing “No-Build” condition without any development on Parcels 24,
25 and 26a (Figure 2-17)
The exhaust flow from the two portals was simulated using a fan system exhausting through the modeled
vehicle tunnels. The pollutants of concern for this assessment were CO, NO2 and PM10.
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Flow visualization tests were initially performed to determine the most likely location of the highest
impacts, and detailed tracer gas tests were performed at the identified high impact locations, including
sensitive public areas, and air intakes of the surrounding buildings.
A full description of the study methodology and results was prepared in the final report Air Quality Study
Dewey Square Portal Boston, Massachusetts, prepared by RWDI, January 2006.
The detailed modeling procedures used for determination of the DST emission impacts and emission
limits can be found in Appendix B, “Air Quality Analysis Protocol for Determination of Emission Limits
as Part of the Operating Certification of the Project Ventilation Systems” of this document.
The dilution factors obtained for the three wind speeds and 24 wind angles for each scenario at each
receptor location for the longitudinally ventilated ramps were used to create a series of matrices. These
matrices provide the tracer gas concentration measured at each receptor location as a percentage of the
full concentration measured at the exit portal (this is the dilution ratio).
This dilution ratio was applied to the full scale source concentration for each pollutant analyzed, and
interpolated using the five years (2000–2004) of meteorological data in order to obtain the highest and
second highest pollutant levels at each receptor location.
The receptor locations were the ambient locations (public access and buildings windows and/or air intake
locations) as used in the 1996 and 2005 physical simulation studies. The site plans and receptor locations
for each ramp are provided in Figures 2-8 to 2-17.
2.5.2.3 CO Analysis
The CO emission source level for the exit ramps was analyzed in the range from 5 to 70 ppm for each
portal. Peak-hour flow conditions (and associated dilution factors) were used for the one-hour analysis,
and 8-hour flow conditions (and associated dilution factors)—for the 8-hour analysis. Five years of actual
meteorological observations were used to come up with the critical source level at which both one and
eight-hour NAAQS is exceeded. The critical source level is identified to the 1 ppm precision. The one
and eight-hour emission limits are established as source levels 1 ppm lower than the critical level or the
highest levels at which both NAAQS are not potentially exceeded.
An in-house program was created to multiply the emission source level by the dilution factor (from the
physical simulation study matrix). This program also interpolates the ratios from the dilution matrix to
account for the actual wind speed and direction at each hour of the year from the meteorological data set
of 5 years. In addition, the program adds the hourly CO background concentration for the respective
hour.
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EPA modeling procedures described in Section 9.3.4.2 of the USEPA Guideline on Air Quality Models
(EPA-450/2-78-027R) were used for calm winds and missing meteorological data. In the case of missing
background CO concentration, the program sets the level for that specific hour to zero. This also follows
the procedures provided in the reference cited above.
The program output prints the 1st and 2nd highest levels for each source strength for the year indicating the
date and hour of occurrence.
Eight-hour analysis procedure is based on the average of eight sequential one-hour results printing the 1st
and 2nd non-overlapping highest levels for the year indicating date and the ending hour of the eight-hour
period.
Carbon Monoxide 1- and 8-hour levels for NAAQS compliance demonstration are presented in Tables 2-
12 through 2-24. These are 2nd highest concentrations. (The use of 2nd highest concentrations follows the
EPA requirements for compliance with CO NAAQS.)
TABLE 2-12: 1- AND 8-HOUR CO LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP LC-S
Ramp LC-S
One Hour CO Eight Hour CO
Year Receptor Source CO 2nd Highest Level Date Hour Receptor Source CO 2nd Highest Level Date Ending Hour
2000 4 70 19.9 11/03/00 19 4 40 8.9 02/18/00 10
2001 4 70 18.9 03/18/01 03 4 41 8.9 08/19/01 8
2002 4 70 19.6 02/10/02 03 4 39 8.8 08/13/02 10
2003 4 70 19.1 05/03/03 22 4 40 8.8 08/29/03 8
2004 4 70 19.0 06/30/04 21 4 41 8.8 11/21/04 18
TABLE 2-13: 1- AND 8-HOUR CO LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP SA-CN
Ramp SA-CN
One Hour CO Eight Hour CO
Year Receptor Source CO 2nd Highest Level Date Hour Receptor Source CO 2nd Highest Level Date Ending Hour
2000 33 70 8.1 11/09/00 18 33 70 4.7 03/23/00 17
2001 33 70 8.1 07/20/01 11 33 70 4.0 04/25/01 22
2002 33 70 8.1 09/07/02 18 33 70 3.7 02/24/02 20
2003 33 70 8.4 09/08/03 20 33 70 4.7 03/24/03 21
2004 33 70 8.2 03/05/04 18 33 70 3.8 02/20/04 23
TABLE 2-14: 1- AND 8-HOUR CO LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP CN-S
Ramp CN-S
One Hour CO Eight Hour CO
Year Receptor Source CO 2nd Highest Level Date Hour Receptor Source CO 2nd Highest Level Date Ending Hour
2000 23 70 15.2 09/05/00 22 23 64 8.9 12/16/00 13
2001 23 70 15.0 03/02/01 08 23 59 8.9 12/13/01 10
2002 23 70 14.9 03/13/02 06 23 65 8.970 10/30/02 22
2003 23 70 15.2 12/19/03 20 23 65 8.9 11/27/03 14
2004 23 70 15.0 04/26/04 21 23 58 8.9 11/17/04 10
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TABLE 2-15: 1- AND 8-HOUR CO LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP ST-CN
NO PARCEL 6
TABLE 2-16: 1- AND 8-HOUR CO LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP ST-SA
NO PARCEL 6
TABLE 2-17: 1- AND 8-HOUR CO LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP ST-SA
+ PARCEL 6
Ramp ST-SA + Parcel 6
One Hour CO Eight Hour CO
Year Receptor Source CO 2nd Highest Level Date Hour Receptor Source CO 2nd Highest Level Date Ending Hour
2000 34 70 17.3 12/11/00 10 34 48 8.9 01/02/00 9
2001 34 70 17.7 12/05/01 21 34 52 8.963 09/18/01 24
2002 34 70 16.6 10/22/02 24 34 54 8.970 07/27/02 8
2003 34 70 16.3 05/26/03 01 34 51 8.961 12/10/03 9
2004 34 70 16.8 10/13/04 18 34 54 8.975 12/03/04 9
TABLE 2-18: 1- AND 8-HOUR CO LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP CS-SA
+ PARCEL 12
Ramp CS-SA + Parcel 12
One Hour CO Eight Hour CO
Year Receptor Source CO 2nd Highest Level Date Hour Receptor Source CO 2nd Highest Level Date Ending Hour
2000 11 70 23.9 03/23/00 03 11 37 8.998 11/20/00 14
2001 11 70 23.1 01/08/01 10 11 33 8.8 01/14/01 22
2002 11 70 24.2 00/17/02 02 11 38 8.9 07/30/02 8
2003 11 70 23.3 09/16/03 20 11 38 8.8 11/27/03 9
2004 11 70 23.9 01/27/04 17 11 37 8.9 11/18/04 8
TABLE 2-19: 1- AND 8-HOUR CO LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP CS-SA
NO PARCEL 12
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TABLE 2-20: 1- AND 8-HOUR CO LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP CS-P
Ramp CS-P
One Hour CO Eight Hour CO
Year Receptor Source CO 2nd Highest Level Date Hour Receptor Source CO 2nd Highest Level Date Ending Hour
2000 20 70 15.0 11/19/00 23 20 70 3.5 01/30/00 8
2001 20 70 14.8 05/07/01 07 20 70 3.9 12/10/01 10
2002 20 70 14.8 07/04/02 04 1 70 3.4 07/15/02 18
2003 20 70 14.5 10/01/03 10 19 70 3.4 11/24/03 8
2004 20 70 13.6 04/18/04 02 1 70 3.3 01/04/04 10
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The Ozone Limiting Method (OLM) was utilized to determine the critical concentrations. Peak-hour flow
conditions (and associated dilution factors) were used to estimate one-hour impacts. Five years of actual
background measurements of NO2 and O3 concentrations at Roxbury and East Boston were used in the
analysis. Five years of actual meteorological observations at Logon International Airport were also used
in the analysis. The critical source level is identified to the 1 ppm CO precision. The one-hour emission
limit is established as a CO source level 1 ppm lower than the critical level. The critical level is the
highest level at which the Mass DEP Guideline Concentration is not exceeded.
A program was developed to perform the OLM analysis. This program determines the NO2 level that is
exhausted from the tunnel and multiplies it by the dilution factor (from the physical simulation study
matrix) to estimate concentrations at the sensitive receptors. It interpolates the ratios from the dilution
factor matrix to account for the actual wind speed and direction at each hour of the year from the
meteorological data set of 5 years. Calm conditions and missing data are treated in the same fashion as
described in CO analysis procedures.
The program outputs the 1st and 2nd highest levels for the year and for each emission source strength
analyzed and indicates the date and hour of occurrence. If the level for a specific hour exceeds the Mass
DEP Guideline level, the background ozone and NO2 concentrations for this hour are also printed.
One-hour Mass DEP NO2 guideline level of 0.17 ppm was not exceeded at the portals of the
longitudinally ventilated ramps and the DSTs as shown in Tables 2-25 through 2-37:
TABLE 2-25: 1-HOUR NO2 LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP LC-S
Ramp LC-S
Year Receptor Source CO Source NOx 2nd Highest NO2 Date Hour
2000 4 70 8.88 0.167 09/20/00 15
2001 4 70 8.88 0.160 03/18/01 3
2002 4 69 8.75 0.169 08/13/02 6
2003 4 52 6.64 0.169 06/25/03 18
2004 4 70 8.88 0.156 05/06/04 18
TABLE 2-26: 1-HOUR NO2 LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP SA-CN
Ramp SA-CN
Year Receptor Source CO Source NOx 2nd Highest NO2 Date Hour
2000 33 70 8.88 0.115 06/20/00 19
2001 33 70 8.88 0.130 08/09/01 22
2002 33 70 8.88 0.142 08/13/02 10
2003 33 70 8.88 0.136 06/26/03 16
2004 33 70 8.88 0.120 06/08/04 13
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TABLE 2-27: 1-HOUR NO2 LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP CN-S
Ramp CN-S
Year Receptor Source CO Source NOx 2nd Highest NO2 Date Hour
2000 23 70 8.88 0.153 06/01/00 18
2001 23 70 8.88 0.154 11/23/01 7
2002 23 70 8.88 0.158 08/13/02 17
2003 23 66 8.38 0.169 06/26/03 19
2004 23 70 8.88 0.134 04/18/04 5
TABLE 2-28: 1-HOUR NO2 LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP ST-CN
NO PARCEL 6
Year Receptor Source CO Source NOx 2nd Highest NO2 Date Hour
2000 9 70 8.88 0.118 06/10/00 15
2001 9 70 8.88 0.138 08/09/01 21
2002 9 70 8.88 0.142 08/13/02 18
2003 9 70 8.88 0.134 06/27/03 14
2004 9 70 8.88 0.123 06/08/04 22
TABLE 2-29: 1-HOUR NO2 LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP ST-SA
NO PARCEL 6
Year Receptor Source CO Source NOx 2nd Highest NO2 Date Hour
2000 34 70 8.88 0.157 06/20/00 24
2001 34 70 8.88 0.139 08/09/01 21
2002 34 70 8.88 0.154 08/13/02 17
2003 34 70 8.88 0.160 06/25/03 17
2004 34 70 8.88 0.127 03/26/04 6
TABLE 2-30: 1-HOUR NO2 LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP ST-SA
+ PARCEL 6
Year Receptor Source CO Source NOx 2nd Highest NO2 Date Hour
2000 34 70 8.88 0.168 06/09/00 24
2001 34 70 8.88 0.162 12/05/01 18
2002 34 70 8.88 0.167 08/13/02 3
2003 34 70 8.88 0.167 06/27/03 2
2004 34 70 8.88 0.143 07/21/04 23
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TABLE 2-31: 1-HOUR NO2 LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP CS-SA
+ PARCEL 12
Year Receptor Source CO Source NOx 2nd Highest NO2 Date Hour
2000 11 50 6.4 0.168 06/21/00 1
2001 11 44 5.65 0.169 05/02/01 13
2002 11 51 6.52 0.168 03/31/02 1
2003 11 51 6.52 0.169 06/25/03 18
2004 11 62 7.88 0.169 01/27/04 17
TABLE 2-32: 1-HOUR NO2 LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP CS-SA
NO PARCEL 12
Year Receptor Source CO Source NOx 2nd Highest NO2 Date Hour
2000 3 60 7.64 0.169 06/20/00 24
2001 3 56 7.14 0.169 05/02/01 13
2002 3 66 8.38 0.169 08/13/02 9
2003 34 63 8.01 0.169 06/26/03 18
2004 33 70 8.88 0.156 06/08/04 22
TABLE 2-33: 1-HOUR NO2 LEVELS FOR COMPLIANCE DEMONSTRATION: RAMP CS-P
Ramp CS-P
Year Receptor Source CO Source NOx 2nd Highest NO2 Date Hour
2000 20 70 8.88 0.134 02/15/00 24
2001 1 70 8.88 0.140 06/20/01 11
2002 1 70 8.88 0.150 08/13/02 17
2003 1 70 8.88 0.139 01/01/00 1
2004 1 70 8.88 0.123 06/08/04 22
Ramp F
Year Receptor Source CO Source NOx 2nd Highest NO2 Date Hour
2000 29 70 8.88 0.114 09/09/00 11
2001 15 70 8.88 0.132 08/09/01 22
2002 22 70 8.88 0.141 08/13/02 18
2003 22 70 8.88 0.134 06/26/03 17
2004 29 70 8.88 0.12 05/12/04 21
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Year Receptor Source NOx Source CO 2nd Highest NO2 Date Hour
2000 27 4.54 35 0.162 07/02/00 16
2001 27 3.3 25 0.165 06/20/01 13
2002 27 2.92 22 0.169 08/13/02 16
2003 27 3.3 25 0.169 06/27/03 12
2004 27 4.54 35 0.162 07/30/04 15
Year Receptor Source NOx Source CO 2nd Highest NO2 Date Hour
2000 23 4.54 35 0.166 07/03/00 4
2001 23 2.92 22 0.168 08/03/01 17
2002 19 2.8 21 0.168 08/13/02 16
2003 23 3.3 25 0.169 07/04/03 23
2004 23 3.92 30 0.169 06/08/04 22
Year Receptor Source NOx Source CO 2nd Highest NO2 Date Hour
2000 4 4.54 35 0.168 06/20/00 23
2001 19 4.54 35 0.168 06/20/01 13
2002 19 3.3 25 0.169 08/13/02 16
2003 4 4.54 35 0.169 06/27/03 2
2004 19 5.16 40 0.163 07/30/04 15
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The Central Transportation Planning Staff (CTPS) model area encompasses 164 cities and towns in
Eastern Massachusetts, as shown in Figure 2-18Figure 2-18 The CA/T Project area is shown in Figure
2-19Figure 2-19. The modeled area is divided into 986 internal Traffic Analysis Zones (TAZs). There
are 101 external stations around the periphery of the modeled area that allow for travel between the
modeled area and adjacent areas of Massachusetts, New Hampshire and Rhode Island.
The model set simulates travel on the entire Eastern Massachusetts transit and highway system. It
contains all Massachusetts Bay Transportation Authority (MBTA) rail and bus lines and all private
express bus carriers. The model contains service frequency, routing, travel time and fares for all these
lines. In the highway system, all express highways and principle arterial roadways, and many minor
arterial and local roadways are included.
A Network was prepared by CTPS to include the Central Artery, as it existed prior to construction of the
CA/T Project. A list of projects included in the No-Build network is shown in Table 2-38. Next, a future
Build network was developed that includes the CA/T Project in full operation, along with the transit
projects that were included in the State Implementation Plan. A list of those projects is also included in
Table 2-38. Certain transit projects have been delayed, including Blue Line Platform Lengthening, Blue
Line/Red Line Connector, Green Line Extension to Medford Hills, the Old Colony Commuter Rail
extension to Greenbush, and additional Orange Line vehicles, and have been addressed in the 2002 and
2005 Amendments to the ACO. None of these delayed transit projects were included in the 2005 Build
and No-Build Network. It is worth noting, however, that even though these delayed transit projects have
not been included, the CA/T air quality analysis performed for the Operating Certification demonstrated
that based on most current traffic data and emission analysis, the operation of the CA/T Project’s tunnel
ventilation system does not cause or result in a violation of any of the certification criteria set forth in the
Ventilation Certification Regulation.
There are other transportation related components contributing to VOC emissions, which cannot be
handled directly within the model. These are:
• The pollutants emitted by the Diesel Locomotives of the Commuter rail system
• The pollutants emitted by the MBTA bus system
• The pollutants emitted by the commuter ferries
The pollutants from the categories above can be estimated outside of the model and included with the
vehicular emissions calculated within the model. The following paragraphs describe the general off-
model procedure that will be used to handle these categories.
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Commuter Ferries
The daily VOC were estimated based on fuel consumption supplied by the ferry operators, and the EPA
pollutant emission factors for marine gas and diesel engines. It was assumed that one third of the fuel
consumption of the whole Metropolitan Planning Organization (MPO) area occurs within the CA/T
Project area.
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Tables 2-39 to 2-42 provide the daily VMT and VOCs for the vehicular network and the off-network
MBTA buses, commuter railroad and ferries. It is important to notice that the CA/T Project results in
significant reductions on VMT and VOCs at the motor vehicle network level, and increases in the public
transit off-network analysis. This is a direct result of a reduction on motor vehicle travel and an increase
in transit service.
TABLE 2-39: NETWORK-BASED DAILY VMT (VEHICLES MILES TRAVELED) AND VOCS
(KG/DAY)
Table 2-43 provides the total cumulative (motor vehicle and transit) VMT and VOC which results in a net
reduction of VOC with the CA/T Project and transit commitments.
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The results (provided in Table 2-43) demonstrate that the CA/T Project result in a reduction of VOC
within the Project affected area when compared to the No-Build condition for all regional scales analyzed.
As anticipated, the highest percentage reduction (13.6%) is for the CA/T Project area, and the lowest
(10%) is for the EMRP area.
In order to allow for traffic growth in the tunnels and also to provide flexibility in operating the tunnel
ventilation system, the hypothetical tunnel operating conditions analyzed are proposed to be adopted as
the VB operating emission limits as follows:
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LC-S 52 6.64 39
SA-CN 70 8.88 70
CN-S 66 8.38 58
ST-CN no Parcel 6 70 8.88 70
ST-SA + Parcel 6 70 8.88 48
ST-SA no Parcel 6 70 8.88 51
CS-SA + Parcel 12 44 5.65 33
CS-SA no Parcel 12 56 7.14 46
CS-P 70 8.88 70
F 70 8.88 70
DST Configuration 1 (Full Build) 22 2.92 22
DST Configuration 2 (Partial Build) 22 2.92 23
DST Configuration 3A (Existing) 25 3.30 23
2.6.3 VOC
The results of the regional modeling demonstrate that the CA/T Project results in a reduction of VOC
within the Project affected area when compared to the No-Build condition for all regional scales analyzed.
As anticipated, the highest percentage reduction (13.6%) is for the CA/T Project area, and the lowest
(10%) is for the EMRP area.
Based on this analysis the VOC for the CA/T Build condition – 6,095.9 Kg/day – should be used as a
budget limit not to be exceeded in the future years.
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Emissions Monitoring
(a) “Any person who constructs and operates a tunnel ventilation system which is
subject to the requirements of 310 CMR 7.38 shall, prior to commencing
operation of the tunnel ventilation system or opening the project roadway for
public use, develop and submit to the Department for review and approval an
“Air Emissions Monitoring Protocol” and shall install and operate emissions
monitoring and recording equipment in accordance with the approved protocol.
Monitoring as approved by the Department shall be required at the exhaust stacks
or exhaust plenums of VBs as well as at exit portals that utilize longitudinal
ventilation. The Department will consider for approval hybrid monitoring
systems that incorporate elements of the federal regulations for monitoring
ambient air pollution, for monitoring stationary source emissions, and for
pollutant emission trading (i.e., 40 CFR Parts 58, 60, and 75) as practicable, as
well as statistical analysis, computer modeling, and innovative technologies. The
“Air Emissions Monitoring Protocol” may also be modified with prior written
approval of the Department.”
Traffic Monitoring
(b) “Any person who constructs and operates a tunnel ventilation system which is
subject to the requirements of 310 CMR 7.38 shall install, operate and maintain
traffic monitoring equipment within the project area, the numbers and locations
of which shall be determined in consultation with the Department.”
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ventilation zone feeds two or three exhaust fans (depending on air flow to be delivered). As examples:
there are six exhaust stacks at VB 6 serving two ventilation zones; and 14 stacks at VB 7 serving five
ventilation zones. This duplication provides redundancy and sufficient ventilation capacity during the
times when fans have to be taken out of service due to maintenance or repairs.
The number of exhaust fans in operation at a given time depends on the control of airflow to and from
various section of the tunnel. This is accomplished by the ventilation control system. The amount of
ventilation depends on the in-tunnel CO measurements, which are dependent on the traffic characteristics.
As such, the amount of the airflow exhausted through each stack could vary from zero to full exhaust
capacity depending on the number of operating fans.
In general, there are always some fans in stand-by mode. Therefore, it was not considered cost effective
to install equipment to continuously monitor emission levels at each stack, when only some are in
simultaneous operation. Instead, vehicular emissions in the tunnel are monitored in the exhaust plenums
of each ventilation zone prior to being diverted up and out of the building stacks. This captures the
totality of exhaust emissions before they are diverted into a particular stack.
The CO monitoring system employs a “rake probe” to gather the samples. The probe consists of a length
of one half inch Teflon or stainless steel tubing. Each of the probes had 8 equal distant holes drilled so
that they allowed for sample collection along the entire width of the ventilation plenum. The probe is
oriented so that the 8 holes are directed into the direction of flow of the source stream.
The PM10 monitoring system also is deployed at the exhaust plenums, but has a single inlet probe at the
center of each exhaust plenum. Tests performed during 2003/04 with multiple portable MiniVOL
samplers indicated minimum variation of PM10 levels across the plenum cross section.
The CO monitoring system employs a similar “rake probe” with eight equal distant holes to gather the
samples. Such probe is located across the roadway at the tunnel ceiling level approximately 100 feet
inside each exit portal (Figure 3-1). These measurements provide an average of the in-tunnel CO levels
before exiting to the atmosphere.
A CEM PM10 monitoring system is also deployed just outside the east portal of longitudinally ventilated
exit ramp CS-SA. This monitor measures ambient PM10 concentrations in the vicinity of ramp CS-SA.
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CO Probe
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The calibration system that is used to calibrate each CO analyzer uses cylinders of CO gas and a “zero”
air source. The CO calibration gas used has been certified according to the EPA RATA procedures. The
“zero” air source uses a zero air generator. Zero air and CO gas is diluted using a multi-gas calibration
system. The calibration system is capable of controlling and mixing the CO calibration gas stream with
the zero air stream to produce concentrations over the entire range of the analyzer. The calibration system
supplies calibration gas through the calibration line to the sample probe at the calibration flow rates that
range between 10 and 15 standard liters per minute (slpm). Calibration gases are injected through the
entire sample line so that the sample line pump is constantly drawing an adequate calibration sample to
the CO analyzer.
The sample/calibration bundle is comprised of two Teflon lines. The sample lines are connected to each
sample probe, through a particulate filter (at the probe end of the line). The sample is drawn from the
probe by a positive displacement pump that discharges to a tee. One leg of the tee is connected to an
atmospheric vent and the other leg of the tee is connected to a fine particulate filter just prior to entering a
CO analyzer. The sample line pump is set to operate so that the velocity in the sample line is sufficient so
that sample residence time in the sample line is always less than 20 seconds. The second line in the
sample/calibration bundle is a Teflon line that is connected from the calibration system to the sample
probe.
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PM10 CEM equipment located at VB 3 is continuously monitoring particulate emissions from vehicles
traveling on north and southbound I-93 tunnel sections. PM10 equipment located at VB 5 and VB 7,
continuously monitor PM10 emissions from vehicles traveling on east and westbound I-90 tunnel sections.
Where :
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Low-level calibration gas with a value of 40 to 50 ppm were input through the entire monitoring system
for 30 minutes, or until a stable response was achieved. At the end of the period, a high-level calibration
gas with a value of 80 to 90 ppm was input through the entire monitoring system for 30 minutes or until a
stable response occurred.
The amount of time it took for 95% of the step change to be achieved between a stable low level and
high-level calibration gas response was determined. The cycle time test was successful was the response
time achieved was less than 15 minutes.
The linearity of the monitoring system to the low and high scale calibration gases was also tested during
the cycle time test. To pass the linearity test, the monitoring system response had to be within +5% of the
low and high-level calibration gas input values using the formula:
Where:
System Response = Concentration recorded by the analyzer when the calibration gas is injected through
the entire system
To pass the seven-day drift test for the zero point, each analyzer’s zero drift could not be greater than
+1% (1.5 ppm) of the analyzer full-scale range (150 ppm) per day. Drift for the span gas was calculated
as follows:
Where :
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System Response = Concentration recorded by the analyzer when the calibration gas was injected
through the entire system
Direct Analyzer Response = Concentration recorded by the analyzer when the calibration gas was
injected directly into the analyzer
In all cases, the manufacturer recommended procedures specified in the PM10 unit’s operating manuals
were applied for all certifications tests. Reference standards used were either primary standards or
working standards traceable to National Institutes of Standards and Technology (NIST).
3.4.2.1 K Factors
% Error of Ko = 100 x (Average Ko – Actual Ko) /Designated Flow
3.4.2.2 Flow
% Error of Flow = 100 x (Average Flow – Designated Ko)/Designated Flow
The allowable temperature error is ± 2oC. The allowable barometric pressure error is ± 10 mm Hg.
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Specifically, the Project has selected four locations where hourly traffic volumes will be recorded, as
follows:
• I-93 southbound in the vicinity of Causeway Street
• I-93 northbound in the vicinity of South Station
• I-90 westbound in East Boston
• I-90 eastbound in the vicinity of Fort Point Channel
These locations represent the tunnel sections that account for the vast majority of the Project’s traffic
volumes, and as such, they will provide Mass DEP with a very good indication of the peak hourly and
daily traffic volumes passing thru the CA/T tunnels.
The QA/QC program sets forth, among other things, the procedures to be followed and the criteria to be
met, where applicable, for:
• operating, maintaining and calibrating the CEMS equipment and related components,
• determining the quality of the measured data, and
• developing emissions-related parameters or directly reporting the measurement results to the Mass
DEP in order to demonstrate project compliance status with respect to the ambient concentration
limits in 310 CMR 7.38(2)(a).
The QA/QC program has been developed through extensive technical consultation with the Mass DEP
taking into consideration Federal Regulations 40 CFR Parts 58, 60 and 75. The procedures to be followed
also take into account equipment manufacturer’s recommendations as well as good engineering practice.
QC, as it is to be implemented for this monitoring program, represents the series of routine and periodic
operational activities (based on regulatory requirements, good engineering practice, and the agreed-upon
approach for this hybrid monitoring system) that are necessary for maintaining and improving data quality
and the instruments and systems that produce that information.
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QA checks also serve to ensure that the QC function is not only being implemented properly, but that it is
adequate to the task, such that when (or even before) data accuracy or documentation becomes
unacceptable, actions are taken to identify and resolve the issues or procedural steps affecting data quality
until acceptable performance is once again achieved. Periodic review of implementation and
documentation are typically referred to as “Systems Audits”.
Corrective action encompasses both internal policies and regulatory requirements. This QA/QC program
focuses primarily on the corrective actions required to return an out-of-control system or component back
to a status of compliance; but, it also acknowledges the need for periodic review of the CEM Air
Emissions Monitoring Protocol and related standard operating procedures (SOPs) based on accumulated
operating experience and opportunities for improvement identified as a result of Systems Audits.
In order to do so, MTA is committed to installing, certifying, operating, maintaining and calibrating
continuous emissions monitoring and related systems in accordance with applicable Commonwealth of
Massachusetts regulations at 310 CMR 7.38(8) and 7.38(9), agreed-upon requirements adapted from
Federal regulations conditions in the CA/T Project’s Operating Certification, the QA/QC program laid out
in Attachment 1, and good engineering practice.
Regarding implementation of the monitoring program, the duties of the Senior Environmental Engineer
encompass:
• procurement of equipment, related components and materials;
• training and supervision of air quality staff, participating in the operation, maintenance and
calibration of the CEMS equipment and related components, and interpreting CEMS output by the
DAHS;
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• ensuring that routine and periodic QC inspections, instrument response checks, calibrations and
adjustments are performed and documented as required;
• verifying that measurement and QC check data are recorded and reviewed on a regular basis, and that
measurement data are reduced and validated properly;
• review, approval and timely submittal of monthly (first year of full operations only) and quarterly
(thereafter) reports of CEMS data and QC check results;
• supporting periodic independent and third-party QA Performance and Systems Audits in coordination
with QA Management, regulatory agencies (as applicable), and any subcontractor(s) that may conduct
such work;
• review and timely submittal of semi-annual QA Performance Audit and annual Systems Audit reports;
and
• resolution of any issues resulting from routine operations, maintenance, QC checks or QA audits,
evaluating the need for Monitoring Plan revision in coordination with QA Management and, when
required, revising the CAEMP or the accompanying SOPs;
• daily review of CO and PM10 measurement data and periodic review of calculated NOx concentrations
for each monitoring location in relation to the corresponding Operating Certification limits, traffic
volumes and tunnel operating conditions;
• regular review of QC check results (i.e., daily CO analyzer response checks) versus applicable
acceptance criteria and action limits;
• routine processing and summarization of measured hourly average CO concentrations, calculated
hourly average NOx concentrations, daily (24-hour) average PM10 measurements, and daily and
periodic QC check results;
• validation of CO and PM10 measurement data based on operating status of analyzers and related
instrumentation, and the results of daily QC response checks (CO only), other periodic QC checks
(e.g., multi-point calibrations, flow rate verifications), and periodic QA Performance Audits;
• preparation of monthly (first year of full operations only) or quarterly (thereafter) reports of CEMS
data, QC check results, and excess emissions (if any) in accordance with 310 CMR 7.38(9)(a)(2);
• supporting preparation of semi-annual QA Performance Audit reports and annual QA Systems Audit
reports;
• retaining all measurement data, results of periodic QC checks and QA Performance and Systems
Audits, and other related documentation (e.g., records of routine and periodic inspections and
preventive maintenance) for a period of at least five years in accordance with 310 CMR 7.38(9)(a)(1);
• the conduct of periodic independent QA Performance Audits - for example, semi-annual multi-point
calibration response and bias checks of the CO analyzers, and semi-annual verification of PM10 mass
transducer calibration and flow audit response;
• the performance of annual independent QA Systems Audits of monitoring program implementation
and related documentation;
• the scheduling and conduct of any third-party (i.e., regulatory agency) QA Performance or Systems
Audits; and
• the preparation and review of the corresponding QA Performance and Systems Audit reports.
If necessary, Data Management responsibilities may be integrated with the responsibilities of the Senior
Environmental Engineer and/or his designee (e.g., Environmental Engineer, Environmental Technicians).
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As indicated at the end of the preceding subsection, the Environmental Engineer and/or Environmental
Technicians may undertake some of the Data Management responsibilities if so assigned by the Senior
Environmental Engineer.
At a minimum, recipients of Controlled Copies of the CEM Air Emissions Monitoring Protocol
(Attachment 1) will include:
• Director of Environmental Engineering
• Senior Environmental Engineer
• Environmental Engineer
• Environmental Technicians
Uncontrolled copies will also be distributed to individuals or organizations on an as-needed basis for
informational purposes where casual familiarity with the monitoring program may be beneficial but is not
essential. The Senior Environmental Engineer in coordination with the Director of Environmental
Engineering shall approve such recipients.
Distribution of Controlled Copies of the CEM Air Emissions Monitoring Protocol, and revisions to it, will
be documented on form MTA-ENV-FORM01. Recipients shall sign the distribution form, return the
original to the Senior Environmental Engineer or designee, and retain a copy of the signed form. The
signed original shall be retained by the Director of Environmental Engineering.
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Distribution of Uncontrolled Copies of the CEM Air Emissions Monitoring Protocol shall be by formal
transmittal letter or e-mail, as appropriate. Documentation of all such transmittals shall also be retained
by the Director of Environmental Engineering.
The CEM Air Emissions Monitoring Protocol may be updated periodically as operational experience with
the CEM system is gained, as the effectiveness of the SOPs and the staff’s execution of them is
demonstrated (as evidenced by the quality of the data and related documentation produced), and as
evaluated through the results of periodic QA Performance and Systems Audits.
At a minimum, the CEM Air Emissions Monitoring Protocol will be reviewed annually by the Senior
Environmental Engineer in coordination with QA Management; more frequently, if required (e.g., due to
failure of multi-point calibrations or an intervening semi-annual QA Performance Audit during two
consecutive calendar quarters, frequently occurring out-of-control periods).
Revisions to any requirement of the CEM Air Emissions Monitoring Protocol (e.g., the frequency of
equipment and data inspections, instrument response checks, calibration checks and adjustments) or to
SOPs shall be agreed upon by the Senior Environmental Engineer and QA Management before
incorporation. All changes to the CEM Air Emissions Monitoring Protocol shall be clearly marked on
each affected page with the Revision Number, Date and Page Number updated accordingly. Controlled
Copies of the affected sections (or subsections), or an individual SOP shall be re-issued by the Senior
Environmental Engineer with distribution and receipt to be documented as described above. The Senior
Environmental Engineer or designee shall keep a chronological log that summarizes all such revisions.
The Senior Environmental Engineer will identify all parties directly affected by such revisions and will
coordinate the necessary training to implement those changes in a timely manner. The appropriate mode
of training shall be at the discretion of the Senior Environmental Engineer.
4.2 TRAINING
Training represents an essential element of a successful QA/QC program by identifying the objectives to
be accomplished and by providing the basic knowledge required to successfully complete a procedure or
task. In this QA/QC program, training takes the form of:
• general training,
• specialized vendor training,
• monitoring plan review, and
• periodic refresher and specialized training
Training and subsequent implementation can also provide a more thorough understanding (over time) of a
given task or procedure that enables the individual involved to make more timely and effective decisions
while executing the process or improving on the process itself. Therefore, training is the cornerstone of
the framework within which activities are performed in a consistent manner regardless of who completes
them.
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When changes in personnel or assigned responsibilities take place, the degree of specialized training will
be tailored to the level of previous experience with the CA/T Project’s continuous air emissions
monitoring program, specific systems, and tasks to be performed. Specialized training in the operation,
maintenance and calibration of the various monitoring systems and components may be conducted by the
vendor or by previously trained in-house staff.
Finally, when system components change (e.g., the replacement of a pollutant monitor with an instrument
that bases its measurements on a different analytical method – as opposed to the repair or replacement of
a failed part) or software upgrades to the DAHS are made, specialized vendor training will take place for
those personnel whose responsibilities or procedures are affected.
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Title Responsibilities
Director of Environmental Engineering • Overall implementation of the program
Senior Environmental Engineer • Technical oversight of CEM program
• Procure CEMS-related equipment/materials
• Determine training needs of AQ staff and, as required, other program participants
• Supervise Environmental Engineer and Environmental Technicians and support those responsibilities as
needed
• CEMS data and QC check report review/submittal
• QA Performance Audit report review/submittal
• QA Systems Audit report review/submittal
• Revise CAEMP and SOPs (as necessary) and coordinate/conduct associated refresher training
• Daily1 data review
• Data processing and validation
• Prepare CEMS data and QC check reports
• Support preparation of QA Performance and Systems Audit reports
• Coordinate conduct of semi-annual/annual QA Performance Audits and annual QA Systems Audits
• Coordinate preparation/review of Performance and Systems Audits reports
Environmental Engineer • CEMS operation, maintenance and calibration
and/or • Regular CEMS inspections2
Environmental Technicians • Conduct quarterly, semi-annual and annual QC checks
• Support independent QA Performance/Systems Audits
Notes:
1 – Data to be reviewed on a daily basis, nominally, during regular work week (Mon-Fri).
2 -- Each site to be visited 2 times, nominally, per regular work week (Mon-Fri).
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DIRECTOR OF
ENVIRONMENTAL
ENGINEERING
SENIOR
ENVIRONMENTAL
ENGINEER
Administrative
Support
Environmental
Technicians
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MTA-ENV-FORM01
CONTROLLED DOCUMENT DISTRIBUTION FORM
Controlled Document No.: Document Issue Date: Revision No.:
Controlled
Document Holder Organization
Document No.
*** RETURN SIGNED FORM TO SENIOR AIR QUALITY ENGINEER OR DESIGNEE ***
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“(a) Any person who constructs and operates a tunnel ventilation system on or after
January 1, 1991 shall comply with the following record keeping and reporting
requirements:
1. All records and data from the continuous emissions monitors, recorders and
traffic monitors shall be maintained for a period of five years. The most
recent two years of data shall be readily available for Department
inspection.
2. Emissions Reporting. For the first year of operations monthly reports shall
be filed with the Department no later than 30 days following the end of the
preceding calendar month. Said monthly reports shall contain a summary of
continuous monitoring data showing any excursions from allowable
emission limitations contained in the Department's acceptance of the
certification. In the event any of the reported data shows an excursion of the
emission limitations set forth in the acceptance of certification, a written
explanation of any excursion shall be included. Evidence of each
calibration event on the monitoring devices shall be included in such
monthly reports.
3. Traffic Reporting. For the first year of operation monthly reports shall be
filed with the Department no later than 30 days following the end of the
preceding calendar month. Said monthly reports shall contain a summary of
average daily and peak hour counts of vehicle miles traveled as well as
average daily and peak hour vehicle speeds and vehicle hours traveled as
identified through the traffic monitoring network established pursuant to
310 CMR 7.38(8).
4. Tunnel Ventilation System Maintenance. For the first year of operations
monthly reports shall be filed with the Department no later than 30 days
following the end of the preceding calendar month. Said monthly reports
shall contain a summary of routine maintenance checks performed, repairs
of ventilation equipment, amount of time during which ventilation equipment
was not operating in accordance with standard operating procedures and
measures taken to remedy this situation.
(b) After the first year of operation, the reports required by 310 CMR 7.38(9) shall be
submitted to the Department on a quarterly basis, with the first such quarterly report
being due no later than 30 days after the end of the quarter and every three months
thereafter.”
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Peak hourly and average daily traffic volumes at each of the four locations will be reported to Mass DEP
on a monthly basis. The data will also provide the monthly average daily volumes for each location.
Historically, motor vehicle emissions were very dependent on traffic speeds, but recent studies had found
no clear correlation between traffic speeds and measured in-tunnel emission levels. Based on these recent
findings, the Project found no compelling reason to record traffic speeds as part of the continuous traffic
monitoring program. As such only volumes will be recorded and submitted.
A summary of the CO, NOx and PM10 average and peak levels for each VB (Tables 5-1 to 5-6) and
longitudinally ventilated section collected between October 2005 and April 2006 are provided in Tables
5-7 to 5-14. The applicable emission limits for CO, NOx and PM10 are also set forth in these tables.
The collected data indicates that measured CO concentrations range from 1 to 6 ppm during off-peak and
as high as 26 ppm during peak periods. The measured NOx levels range from 0.3 to 0.8 ppm in the off-
peak hours and from 1.3 to 3.2 in the peak hours. The measured average daily PM10 concentrations are in
between 29 and 153 μg/m3 and the measured maximum daily concentrations range from 49 to 365 μg/m3.
Some of the measured peak PM10 levels have been associated with the nighttime construction activities
related to the tunnel leaks. The levels are expected to get lower once the repair and construction process
is finished.
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TABLE 5-1: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: VENTILATION BUILDING 1
Monitor Location: VB1 Exhuast Ducts 1 & 2 (Ramp L/HOV for I-90 EB)
Pollutant Time Period Emission Limits Parameter Unit 10/05 11/05 12/05 01/06 02/06 03/06 04/06
Maximum ppm 9.8 6 3.6 3.4 8.7 3.9 8.7
Average ppm 1.3 1 1.1 0.9 1.4 1.2 1.2
1 Hour 70 ppm
Hours exceed EL 0 0 0 0 0 0 0
CO Hours exceed 80% EL 0 0 0 0 0 0 0
Maximum ppm 4 2.9 3 2.1 6.7 2.6 4.4
8 Hour 70 ppm Hours exceed EL 0 0 0 0 0 0 0
Hours exceed 80% EL 0 0 0 0 0 0 0
Maximum ppm 1.4 0.9 0.6 0.6 1.3 0.7 1.3
Average ppm 0.4 0.3 0.3 0.3 0.4 0.4 0.4
NOx 1 Hour 8.88 ppm
Hours exceed EL 0 0 0 0 0 0 0
Hours exceed 80% EL 0 0 0 0 0 0 0
Monitor Location: VB1 Exhaust Ducts 8 & 9 (Ramp L/HOV for I-90 EB)
Pollutant Time Period Emission Limits Parameter Unit 10/05 11/05 12/05 01/06 02/06 03/06 04/06
Maximum ppm 8.8 6.3 6.1 4.7 9.1 4.1 5.8
Average ppm 2.2 1.7 1.7 1.7 1.7 1.2 1.3
1 Hour 70 ppm
Hours exceed EL 0 0 0 0 0 0 0
CO Hours exceed 80% EL 0 0 0 0 0 0 0
Maximum ppm 7.4 4.2 5.5 2.9 8.1 2.1 3.7
8 Hour 70 ppm Hours exceed EL 0 0 0 0 0 0 0
Hours exceed 80% EL 0 0 0 0 0 0 0
Maximum ppm 1.3 1 1 0.8 1.3 0.7 0.9
Average ppm 0.5 0.4 0.4 0.4 0.4 0.3 0.4
NOx 1 Hour 8.88 ppm
Hours exceed EL 0 0 0 0 0 0 0
Hours exceed 80% EL 0 0 0 0 0 0 0
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TABLE 5-1: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: VENTILATION BUILDING 1
(CONTINUED)
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TABLE 5-2: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: VENTILATION BUILDING 3
Monitor Location: VB3 NB-1
Pollutant Time Period Emission Limits Parameter Unit 10/05 11/05 12/05 01/06 02/06 03/06 04/06
Maximum ppm 5 17.4 8.8 6.2 5.7 6.1 4.4
Average ppm 1.8 1.9 1.4 1.6 2.1 1.3 1.4
1 Hour 70 ppm
Hours exceed EL 0 0 0 0 0 0 0
CO Hours exceed 80% EL 0 0 0 0 0 0 0
Maximum ppm 3.4 7.9 4.6 2.9 4 4.5 3.2
8 Hour 70 ppm Hours exceed EL 0 0 0 0 0 0 0
Hours exceed 80% EL 0 0 0 0 0 0 0
Maximum ppm 0.8 2.4 1.3 1 0.9 1 0.7
Average ppm 0.4 0.4 0.4 0.4 0.5 0.4 0.4
NOx 1 Hour 8.88 ppm
Hours exceed EL 0 0 0 0 0 0 0
Hours exceed 80% EL 0 0 0 0 0 0 0
3
Maximum μg/m 247.5 144.4 235.3 197.6 174.6 141.7 174.7
3
Average μg/m 90.8 85.4 123.5 110.1 88.3 85.2 79.6
PM10 24 Hour 500 mg/m3
Days exceed EL 0 0 0 0 0 0 0
Days exceed 80% EL 0 0 0 0 0 0 0
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TABLE 5-2: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: VENTILATION BUILDING 3
(CONTINUED)
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TABLE 5-3: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: VENTILATION BUILDING 4
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TABLE 5-3: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: VENTILATION BUILDING 4
(CONTINUED)
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TABLE 5-4: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: VENTILATION BUILDING 5
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TABLE 5-4: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: VENTILATION BUILDING 5
(CONTINUED)
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TABLE 5-5: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: VENTILATION BUILDING 6
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TABLE 5-6: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: VENTILATION BUILDING 7
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TABLE 5-6: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: VENTILATION BUILDING 7
(CONTINUED)
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TABLE 5-6: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: VENTILATION BUILDING 7
(CONTINUED)
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TABLE 5-7: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: RAMP LC-S
TABLE 5-8: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: RAMP SA-CN
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TABLE 5-9: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: RAMP CN-S
TABLE 5-10: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: RAMP CS-SA
Notes:
1. Before May 1st, 2006 PM10 levels were recorded inside the tunnel and therefore were not subject to NAAQS.
2. EL = Emission Limit
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TABLE 5-11: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: RAMP CS-P
TABLE 5-12: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: RAMP F
Pollutant Time Period Emission Limits Parameter Unit 10/05 11/05 12/05 01/06 02/06 03/06 04/06
Maximum ppm 4 9.6 3.7 3.9 3.4 3.4 3.7
Average ppm 0.8 1.5 0.9 1.1 0.9 1.4 1.3
1 Hour 70 ppm
Hours exceed EL 0 0 0 0 0 0 0
CO Hours exceed 80% EL 0 0 0 0 0 0 0
Maximum ppm 2.5 3.4 2.8 2.8 2.5 2.5 2.8
8 Hour 70 ppm Hours exceed EL 0 0 0 0 0 0 0
Hours exceed 80% EL 0 0 0 0 0 0 0
Maximum ppm 0.7 1.4 0.7 0.7 0.6 0.6 0.7
Average ppm 0.4 0.4 0.3 0.3 0.3 0.4 0.4
NOx 1 Hour 8.88 ppm
Hours exceed EL 0 0 0 0 0 0 0
Hours exceed 80% EL 0 0 0 0 0 0 0
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TABLE 5-13: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: DST I-93
Notes:
1. EL = Emission Limit
2. Air quality analysis performed for each hour when EL was exceeded demonstrated that no violations of the Massachusetts 1-hour NO2 Policy Guideline Limit had occurred. (Appendix E).
TABLE 5-14: SUMMARY OF CO, NOX AND PM10 AVERAGE AND PEAK LEVELS: DST I-90
Notes:
1. EL = Emission Limit
2. Air quality analysis performed for each hour when EL was exceeded demonstrated that no violations of the Massachusetts 1-hour NO2 Policy Guideline Limit had occurred (Appendix E).
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6 CONTINGENCY PLAN
6.1 GENERAL REQUIREMENTS (310 CMR 7.38(4))
“… the operating certificate submittal shall include a contingency plan consisting of
measures which could be implemented in cases of exceedance of the emission limitations
in the certificate. Said contingency plan shall identify available contingency measures
including, but not limited to, alternative tunnel ventilation system operations and
maintenance, and transportation control measures; a commitment for implementing said
measures; a schedule for implementing measures on a days-to-full effectiveness basis;
and an analysis of the daily air quality impact of the measures on the emissions from the
tunnel ventilation system and within the project area.”
The established emission limits for each location are listed as follows:
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As described in Section 2.4.3 of this document, emission limits for NOx were established using a
statistical analysis of actual CO and NOx emission data collected from the TWT. The 1-hour CO
emission limits listed above were established taking into account 1-hour NO2 impacts. As a result, if the
1-hour CO emission levels remain below the listed emission limit, then no exceedances in the
Massachusetts 1-hour NO2 Policy Guideline Limit should occur.
First, the in-tunnel CO monitoring system that is used to control tunnel ventilation and maintain in-tunnel
air quality, is set to alarm at a 25 ppm CO level. In response to an alarm, an OCC operator will lower the
in-tunnel CO level to below 25 ppm by increasing the ventilation rate at the affected ventilation zone.
The second tier of pre-emptive measures involves the CEM system. The 1-hour CO and 8-hour PM10
CEM emission action levels have been established for each emission location and actions will be taken
(i.e., ventilation of the affected zone or zones increased) to lower the pollutant levels inside the tunnel
when these action levels are exceeded. The action level established for each emission location falls within
a range between 75 to 85% of its respective emission limit as listed below.
Real-time CO emissions for all CO CEM monitoring locations except VB 6 and 7 are provided in the
Operation Control Center for operator use. Using CO action levels presented in Table 6-2, procedures
will be established for the OCC that will trigger an OCC operator response in the event that a CEM action
level is reached.
In order to comply with the lowest emission action level (i.e., 20 ppm for DST), the ventilation fans for
the Dewey Square Air Intake Structure along with ventilation zone SB-1 from VB 3, will be set to step 3
from 3 p.m. to 6 p.m. each weekday afternoon. The increase in the ventilation zone settings should
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prevent hourly CO emission levels from going above 20 ppm for DST. If however, the emission action
level for DST is exceeded because of a non-emergency situation, the ventilation will be stepped up to a
higher setting to ensure emission level remains below the emission action level.
Because of the high CO emission action levels for VBs 6 & 7, recorded CO CEM emission levels will be
tracked for one continuous year. If CO emission levels remain well below the 60 ppm action level listed
in Table 6-2 as anticipated, MTA will not proceed to establish a CO CEM display for these two locations.
However, if CO emission levels are near the 60 ppm action level, then the CEM monitors from VBs 6 &
7 will be displayed in the OCC.
In addition, PM10 CEM emissions levels are also not displayed in the OCC. However, similar to CEM
CO emissions from VBs 6 & 7, CEM PM10 emission levels from VBs 3, 5, 7 and ramp CS-SA will also
be tracked for one continuous year. Likewise, if PM10 emissions are near the 8-hour 500 μg/m3, then
PM10 emission levels will be displayed in the OCC. However, because of the high 8-hour emission action
level of 500 micrograms per cubic meter, it is very unlikely that this level will ever be reached.
In summary, it is extremely unlikely that any of the CEM emission action levels listed in Table 6-2 will
ever be reached due to the deployment of the pre-emptive actions.
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310 CMR 7.38(6) states that if Mass DEP finds—based on a review of information submitted by the
operator in support of the operating certification, and such information as Mass DEP has available to it—
that one or more of the air quality limits set forth in the 7.38 Criteria are being violated or are likely to be
violated, then the operator of the tunnel ventilation system shall take certain identified actions. The
trigger to taking those actions then is a finding of a violation of air quality standards based on Mass DEP
review of the operating certification submittal itself.
It is unlikely that even the emission action levels will be exceeded at any VB or longitudinally ventilated
ramp because of the measures designed to preclude this from happening. Several preventive steps will be
undertaken to ensure compliance with emission limits before any mitigation measures will be considered.
Those steps are described above in sections 6.2 and 6.3. First, tunnel ventilation system is operated to
maintain 25 ppm CO levels inside the tunnel which is below most limits. Secondly, CEM monitoring
system warns operators if the action level (75-85% of emission limit) is reached. Finally, operators will
be alarmed if emission limit is exceeded. In each case, OCC operators will increase ventilation rates in
order to bring emissions in the tunnel below the indicated criteria. If emission limit is still exceeded at
any location, procedures described in section 6.4 above will be followed and an assessment will be
performed to analyze air quality impacts for the particular hour/day of exceedance and to demonstrate
whether an exceedance of the emission limit indeed created an exceedance of the NAAQS or a Mass DEP
Policy Guideline.
The corrective actions established to comply with the contingency plan requirements of 310 CMR 7.38(4)
should be effective in reducing emission levels in the event that any of the established action limits are
exceeded due to non-emergency traffic conditions. Because information regarding the development of a
CA/T mitigation plan is required only in the event that Mass DEP finds that one or more of the 7.38
criteria are being violated, unless and until Mass DEP makes such a finding, including but not limited to
an identification of the nature and severity of the violation, appropriate mitigation measures are not
required to be developed.
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